If your tower has an underground storage tank (UST) being used for an emergency power supply, you will need to make sure it is in compliance for leak detection in new regulations taking effect this Fall for 16 states (AK, AZ, CA, DE, DC, FL, NJ, NY, KY, MI, WI, IL, OH, RI, VT, WY). The rest have until 2021 to reach compliance.
In 2015, the EPA revised the UST regulations requiring owners and operators of emergency power generator UST systems to meet the release detection requirements for tanks and product lines:
- Emergency generator UST systems installed on or before October 13, 2015, must begin meeting the release detection requirements not later than October 13, 2018.
- Emergency generator UST systems installed after October 13, 2015, must meet release detection requirements when they are installed.
“The leak detection for the tanks themselves is not hard to achieve,” Robert May, Senior Engineer and Director of Environmental Compliance for Synergy Environmental in Royersford PA told Inside Towers, “but the leak detection for the piping will require some changes.”
“It is new,” May said, “because all underground storage tanks (USTs) for emergency generators did not have to conform to the leak detection standards like USTs at truck stops or convenience stores.”
Many UST systems have some sort of automatic tank gauge (ATG) to measure the tank inventory level and this equipment may be able to perform the required monthly 0.2 gph leak test. USTs that are double wall can be compliant with leak detection by monitoring a sensor in the interstitial space, but the ATG usually is an upgraded model.
The UST piping system must also have approved leak detection methods. This is problematic since there is typically a pressure product line and suction product line. If the piping is double wall, it may be compliant by monitoring a sensor in a containment component on top of the tank and a sensor where the piping terminates at the generator. UST systems with fuel polishing units, which operate on a time interval and specific duration, would also need the piping monitored for leak detection.
For instance, at a hospital May’s company is working with, the UST has a leak detector but the piping does not. For about $28,000, the hospital could remove the UST and install an aboveground storage tank (AST) and keep the existing piping.
To put leak detection on the piping, it will require a new tank leak detector and new piping, about a $20,000 project.
For some locations, according to May, it could require a new installation of double wall piping for leak detection. This work would also require an environmental assessment when the existing piping is removed. Most states have a standard protocol for soil sampling with the analysis certified by a licensed Geologist or a Professional Engineer.
May said UST owners need to consult with an engineering and environmental consulting firm to devise a pathway to compliance.
July 10, 2018