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bluesnickers
9 Posts |
 Posted - 02/27/2012 : 18:04:30
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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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Tankette
67 Posts |
Posted - 02/27/2012 : 18:27:27
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What state? You should be able to get a High Level Alarm without an ATG. The alarm has to be visible/audible from the tank pad. Having an atg by itself doesn't help you, the "high product limit" alarm that shows up on the atg unit doesn't alert the driver anyway. One of the distributors on here likely has a good solution. I think this is easier than you are thinking it will be. High Level Alarms were in use before ATG. Good luck with the fine. Try negotiating no matter what, but keep your expectations low. Local / state agencies do not always know the federal requirements (and vice versa).
quote:
Originally posted by bluesnickers
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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bluesnickers
9 Posts |
Posted - 02/27/2012 : 18:36:28
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Thank you Tankette. State of Nebraska here.
Like I said, I've called almost all local equipment companies and
one company won't even return my calls, second company says excavation is necessary or atg.
Third one I talked to said almost same thing mentioning atg.
So should I opt for high level alarm without atg?
Then why wouldn't any local company offer this?
Lastly, I'm just worried that since it's going to take some time,
epa would pursue further legal actions. Like I said, they only give you 30 days and
I'm running out of time. |
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Tankette
67 Posts |
Posted - 02/27/2012 : 19:37:48
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I really think the technology exists. You might have to search out info on it yourself and then go back to these contractors better educated. You might want to post in the equipment part of the forum to get some expert opinions.
I've never gotten a violation from EPA. In my state, the DEC issues you a NOV and you need to pay the fine and present a Corrective Action Plan. You propose your solution and lay out the timeframe it will take to achieve compliance. If they don't like it (the plan or the timeframe), they will kick it back. But clearly you have to be making efforts toward compliance (and documenting those efforts) or they will escalate.
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steveold7
USA
190 Posts |
Posted - 02/27/2012 : 19:55:26
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| Do u have a phase I dual point system?Meaning is there a vapor drybreak next to your fill?If so u may or should have an extractor tee on the top of the tank when u remove the drybreak and look down the riser.U should see a 3" threaded hole.If you have that then u can install a ball float which is overfill prevention.Drawback is it can only be set at a maximum of 90% tank capacity as opposed to a overfill drop tube can be set at 95%. |
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bluesnickers
9 Posts |
Posted - 02/27/2012 : 20:49:14
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I'm not sure what phase I dual point system is. But
I've asked 2 different contractors here and BOTH told me ball float is illegal?
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Tankette
67 Posts |
Posted - 02/27/2012 : 20:58:16
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What product is stored in the tank? Do you have vapor recovery (where the vapors from the tank are collected by the delivery truck during delivery)?
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bluesnickers
9 Posts |
Posted - 02/28/2012 : 01:44:17
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NOT dual point sytem for sure, I'll take some pictures of tank setup and post tomorrow.
Hopefully you guys can tell me more.
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Tankette
67 Posts |
Posted - 02/28/2012 : 10:06:49
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| One more question: what type of deliveries does the tank recieve? Pressurized (truck has a pump to push fuel into tank) or gravity drop? |
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Tankette
67 Posts |
Posted - 02/28/2012 : 11:12:13
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| I'm sorry to hear that. I will admit that I would hesitate to operate such an old tank. In my state, they plan to sunset single wall systems. They will require owners to close the systems by a certain date. You may want to find out if that is the case in Nebraska and if so, maybe you do not want to sink another penny into this system. |
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CherokeeUST
USA
407 Posts |
Posted - 03/01/2012 : 08:48:32
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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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The opinions expressed here are entirely mine and are not endorsed by my employer.
Robert |
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bluesnickers
9 Posts |
Posted - 03/05/2012 : 20:42:17
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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 |
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SW_Reid
USA
3 Posts |
Posted - 05/14/2012 : 13:54:17
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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. |
Steven Warren
Environmental Compliance Officer |
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whittingtonm
USA
1079 Posts |
Posted - 05/15/2012 : 13:54:35
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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? |
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Tankette
67 Posts |
Posted - 05/15/2012 : 13:56:17
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| Now? None, unless their state requires it. |
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CherokeeUST
USA
407 Posts |
Posted - 05/16/2012 : 08:35:50
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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. |
The opinions expressed here are entirely mine and are not endorsed by my employer.
Robert |
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