November 28, 2017 | Vol. 67, No. 23
Dear PEI Member:
Since mid-2015, the District of Columbia and 38 states with State Program Approval (SPA) status have been working to update their underground storage tank (UST) regulations. To meet federal Environmental Protection Agency (EPA) requirements, these jurisdictions must amend their existing state plans and reapply for SPA status by Oct. 18, 2018.
As the amendment process unfolds across the country, no single question is receiving more attention than how best to test containment sumps used for interstitial monitoring of piping. Under the 2015 federal regulations, containment sumps used for interstitial monitoring must be tested at least every three years by a vacuum, pressure or hydrostatic method that ensures the sump is liquid-tight. Moreover, this test must be conducted according to:
At present, the federal regulations accept only one code of practice for containment sump testing: PEI/RP1200: Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities. The PEI/RP1200 hydrostatic testing method requires the owner or operator to fill the sump with water to a depth of at least four inches above the sump’s highest penetration or sidewall seam. The sump passes the test if the water level in the sump drops by less than 1/8 inch after one hour. If the water level drops by 1/8 inch or more, the sump fails.
Any SPA state that is uncomfortable with the RP1200 hydrostatic test must adopt an alternative test method that is equally protective of the environment. In the technical compendium accompanying its 2015 federal regulations, EPA has even outlined a package of test requirements it would consider sufficient:
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Although the Petroleum Marketers Association of America (PMAA) is lobbying state regulators to reject the RP1200 method in favor of some form of low-water-level test, the committee that drafted RP1200 continues to believe its recommended procedure offers the best, most balanced and most environmentally protective approach to this important task.
The composition of the RP1200 committee was carefully structured to reflect the diversity of the industry. Experts from large fuel marketers, small fuel marketers, environmental firms, fiberglass and steel tank manufacturer associations, distributors, contractors, testing companies, state regulators and even the EPA itself were all represented.
This diversity ensures that the consensus recommendations in the document took into account the perspectives of all major UST stakeholders. By contrast, the stakeholders advancing alternative test methods represent a much narrower range of interests.
Before reaching its final decisions, the RP1200 committee also actively solicited input from the industry through a lengthy public comment period. Many of the commenters offered suggestions on containment sump testing—from changing the water level to lengthening the test period to adjusting the pass/fail criteria to incorporating other technologies into the analysis. In the end, three fundamental factors led the committee to recommend the high-water-level sump test.
First, any meaningful test must ensure that the sides, bottom and penetration points of the sump are liquid-tight. Penetration points and side seams are the most likely points of failure in sumps. RP1200’s hydrostatic test protocol directly addresses these problem areas. Low-water-level tests do not.
Second, in a busy fueling station environment, containment sump sensors can be and often are jostled, damaged or moved from their designed locations. A test that relies on the accuracy and precise placement of a sensor is inherently risky. Faulty calibration, inadequate anchoring, equipment malfunction or a sensor placed too high in the sump can easily nullify the effectiveness of a low-water-level test. The RP1200 protocol is much more objective and much less prone to error than a sensor-based test.
Finally, alternative sump testing procedures that appear to be more convenient and less expensive may not be over the long term. Comparative data from major testing organizations show that the RP1200 hydrostatic test uncovers more sump failures than low-water-level tests. For owners and operators who truly are interested in protecting the environment, spending a little more now to reduce the risk of an undiscovered leak or catastrophic failure later is a small price.
BIRD REGISTRATION NOW OPEN
Now in its 25th year, UID is a concentrated educational program tailored specifically for professionals in the wholesale distribution industry. Attendees can choose from more than 40 classes to plan a program perfectly suited to their needs. CEOs, branch managers, sales and marketing professionals, operations managers, purchasing and inventory personnel, and manufacturers all can benefit from UID. PEI members who have attended in recent years have given the event rave reviews.
As a proud sponsor of the program, PEI is offering $600 scholarships to the first 30 PEI members who register. PEI also will host a special dinner during the conference just for PEI attendees, providing an excellent opportunity to network with your industry peers.
To view the full menu of courses and register online, visit www.pei.org/uid. Note: Many UID classes sell out well in advance, so early registration is strongly encouraged.
RFA and PMAA also have been busy on Capitol Hill during the past few weeks. PMAA kicked things off with a Nov. 9 letter to the Senate Environment and Public Works Committee stating that “95 percent of all gasoline outlets in the United States cannot legally store or dispense ethanol blends higher than 10 percent.” Four days later, RFA responded, protesting that PMAA’s statistics were “grossly overstated.”
EXECUTIVES CONFERENCE, FEB. 7-9
Open to PEI member company employees age 21-45, the Young Executives Conference fosters an exchange of ideas on everyday business challenges in a relaxed environment that encourages creative thinking.
The conference keynote speaker is Garrison Wynn, author of The Real Truth About Success: What the Top 1% Do Differently, Why They Won't Tell You, and How You Can Do It Anyway! A panel of five industry experts also will discuss “What I Would Tell My Younger Self.” Panelists are:
Early bird registration ($495 for YE members and $595 for non-YE members) ends Dec. 15. Guests who do not work in the industry may enjoy conference receptions and meals for $125. Learn more and register at www.pei.org/ye2018.
New for 2018, PEI member companies interested in reaching these young leaders may secure sponsorships of the conference. View the various sponsorship levels here.
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