| T O P I C R E V I E W |
| bluesnickers |
Posted - 02/27/2012 : 18:04:30
My station was inspected by epa for the first time in August, 2011.
And on February 2, 2012, I get a letter or
"expedited settlement" which has non-negotiable fine of $1050 that needs to be signed and mailed back in 30 days.
I've been in business since 2005 and this was first time from epa.
State fire marshal inspected my station many times without any fine.
Now my question is that I do not have any overfill prevention device nor atg. Plus the fill riser pipes are 3" and can not find 3" drop tube anywhere.
Only option I have is installing atg along with alarm which I'm guessing will cost around $10k.
The problem is that I don't have $10k sitting around.
It's been really slow here for last a couple of years.
What are my options? What should I do?
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| 15 L A T E S T R E P L I E S (Newest First) |
| ZMiller |
Posted - 07/19/2012 : 20:39:22
If you are using suction pump dispensers you can't have ball floats as overfill protection? No inspector is skinny enough to squeeze down a fill or vent riser to look for ball floats. Three inch 10% shutoff fill tubes can still be found and installed. Let me know if you go that route and I'll dig (find) some up. I often tell inspectors to carry a mirror for looking for tank top ball floats inside the tank. |
| MarkWallace |
Posted - 07/19/2012 : 17:25:10
OPW makes 3-inch 95% OF valves. |
| whittingtonm |
Posted - 05/29/2012 : 07:16:29
Tankette, They seem to work. Truck drivers still jam them open with sticks, etc.
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| Tankette |
Posted - 05/24/2012 : 12:43:01
I've always wondered: Do ball floats and flappers "fight"? If the rate of delivery is slowed at 90%, does the flapper produce that hard closure (hose jump)? When we upgrade to auto shut off valves, we try to remove or destroy the ball valves. |
| whittingtonm |
Posted - 05/24/2012 : 12:33:31
When I said we had installed them, it was always as a back-up to an electronic overfill alarm and flapper valve in the drop tube. I should have pointed that out.
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| mrdv |
Posted - 05/23/2012 : 08:12:27
There really is no test protocol. Its more of a functionality inspection. The only thing you can do is remove the ball float. Verfiy the ball and casing is intact. And verify it is at 90% or less nominal capacity inside the tank. I've had the EPA and state witness this before.
I've also "heard" but have no actual evidence that an overfill with BFV's can cause FRP tanks to crack at the riser where the BFV is located due to the sudden jolt. I'm not sure if I buy this but can see how its possible. |
| CherokeeUST |
Posted - 05/17/2012 : 07:32:46
We've known for years that ball floats are a serious issue. They can cause the delivery drivers to get soaked in fuel. They can fail and no one would know until too late. They can rust and get holes in the ball or the cage can rust out and the ball can float off. My sites, hopefully, have moved away from them years ago. Alarms also depend too much on humans.
Flappers also fail. We were doing a tank lining inspection, when the drop tubes were pulled out we realized the float was gone off of one of the flapper valves.
The final comment period for the new regs ended, but when will they be finalized? We will see then if Ball Floats will be allowed anymore.
We always need to be cognizant of the geographic location of people when giving Compliance advice. My advice is based on the EPA regs. State regs can vary quite significantly, but they are supposed to be at least as stringent as the EPA regs. |
| whittingtonm |
Posted - 05/16/2012 : 13:09:25
Tankette, Thanks for a clear statement of the requirements and good advice.
The ball floats the my organization has installed for at least the last 15 years or so have been installed with accessible extractor fittings. They can inspected and tested as required. But I have seen some that were simply buried under concrete and inaccessible. Those could not be easily inspected and tested.
As Cherokee UST says, remarks and opinions expressed are completely my own and not those of my employer. |
| Tankette |
Posted - 05/16/2012 : 08:45:51
Under today's federal rules, as long as your state does not prohibit the installation of a ball float, you can still install one today (I'm not saying I would do this, I am speaking only to the regulation). The revision to 40 CFR 280 is proposed only. If you installed a BF today, then once the regulation is enacted, you would be required to inspect / test it regularly. When it fails (and it will fail), you would not have the option of replacing it in kind, you would need to use another method (positive shut off valve or high level alarm). Depending on short or long term plans for a UST, this might be a rational option.
Testing / Inspection will be done in compliance with PEI RP 1200. You can view the draft of that document at www.pei.org. Again, it is not finalized yet, but the feds are relying on it to establish an industry standard for testing the various components of a UST system. The revised regulations refer several times to such a standard, which as of now, does not exist. |
| CherokeeUST |
Posted - 05/16/2012 : 08:35:50
I agree with Tankette. Only time they ever get looked at is if there was a problem.
Have you ever tried to look into the vent port. I thought it would be interesting to push down on the membrane, maybe I could see the BF. It was not a good idea. I got a face full of vapors. And still couldn't tell anything about the BF. |
| Tankette |
Posted - 05/15/2012 : 13:56:17
Now? None, unless their state requires it. |
| whittingtonm |
Posted - 05/15/2012 : 13:54:35
Let me add to SW-Reid's point that under USEPA's proposed rule changes, ball float valves will need to be tested every three years and will need to be removed and not replaced when overfill prevention equipment is changed.
How many folks test ball floats now, and how do they do it, I wonder? |
| SW_Reid |
Posted - 05/14/2012 : 13:54:17
Ball floats are illegal on new builds. But if they are the in place form of overfill protection, depending on when they were installed, are perfectly acceptable.
If the inspector could not verify the presence of ball floats at the time of inspection, he could write the violation.
As far ATG goes, you may need to install one to have an audible or visual alarm to work properly. |
| bluesnickers |
Posted - 03/05/2012 : 20:42:17
quote:
Originally posted by CherokeeUST
Sorry, I've been out with the flu for the last week and did not get in on this earlier.
First, is your site overseen by the State of Nebraska or by the EPA?
EPA would only be coming around if your site is considered to be on Federal or Tribal Lands and then only if the State has not got an agreement in place to regulate your facility. State Fire Marshall may not have issued a fine, BUT if they have been telling you to get something fixed and you have not then you are considered a "Problem
e-mailed you.
child" and they turned you over to the EPA to slap your hands with monetary fines and get your attention. If you don't pay and get the problems fixed, it can and will get worse.
I will try to help you get this fixed. In 1988 the EPA determined you could use three different kind of overfill devices, ball float, Flapper valve or an audible alarm that the delivery driver can hear when dropping fuel into your tanks. Ball float is usually installed under the vent pipe, cannot be seen without dismantling the vapor recovery top, and was outlawed in several states after the energy act of 2005. A flapper valve is usually part of the drop tube and placed inside of your fill port.
What were you fined for? How are you doing your monthly leak detections? What kind of system do you have?
e-mailed you |
| CherokeeUST |
Posted - 03/01/2012 : 08:48:32
Sorry, I've been out with the flu for the last week and did not get in on this earlier.
First, is your site overseen by the State of Nebraska or by the EPA?
EPA would only be coming around if your site is considered to be on Federal or Tribal Lands and then only if the State has not got an agreement in place to regulate your facility. State Fire Marshall may not have issued a fine, BUT if they have been telling you to get something fixed and you have not then you are considered a "Problem child" and they turned you over to the EPA to slap your hands with monetary fines and get your attention. If you don't pay and get the problems fixed, it can and will get worse.
I will try to help you get this fixed. In 1988 the EPA determined you could use three different kind of overfill devices, ball float, Flapper valve or an audible alarm that the delivery driver can hear when dropping fuel into your tanks. Ball float is usually installed under the vent pipe, cannot be seen without dismantling the vapor recovery top, and was outlawed in several states after the energy act of 2005. A flapper valve is usually part of the drop tube and placed inside of your fill port.
What were you fined for? How are you doing your monthly leak detections? What kind of system do you have?
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