SB989 Secondary Containment Testing by Stan … SB989 Secondary Containment Testing by Stan Brodecki XXX Environmental Management Non Testable Secondary Containment Systems and When

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SB989 Secondary ContainmentTesting

by Stan BrodeckiXXX Environmental Management

Non Testable Secondary ContainmentSystems and

When a segment of your SecondaryContainment System Fails

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• History - In 1984 - 1985 the SWRCB adoptednew regulations requiring double wall UST’s andpiping systems.

• These regulations preceded technology as do thenew regulations of today.

• As we all know the first few years that doublewall UST systems were built, only existinghardware and entrepreneurial hardware wasavailable, while more permanent solutions werestill in designed and in testing (UL, Third Party).

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• Many Corporations acting in good faith and asgood corporate citizens went out and installed alarge number of double wall UST Systems from1985 -1992.

• 1992 is about when proven technology startedto catch up with the regulations.

• For Standby/Emergency Generators USTSystems - This technology is still beingdeveloped.

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• Today we are now required to retest our

existing Secondary Containment systemsmany of them dating as far back as 1985.

• Some of the many problems encountered in

trying to test these UST Systems can befound in the design and hardware that wasavailable at the time of installation.

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• Standby/Emergency Generators are particularlydifficult to test because of their design andavailable hardware and technology.

• Following are some of the problems you arefaced with when trying to testStandby/Emergency Generator Systems

• Secondary Contained Piping is particularlydifficult.

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Piping Secondary Containment ends at the building wall.It has been sealed with caulking (Bostick)

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Piping Secondary Containment ends above grade, however theboot and cap will not hold 5 lbs.. PSI air pressure around the

piping.

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Piping secondary ends outside the building SW steel pipingthrough the wall and sealed for weather protection.

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PipingSecondary

containmentends above

grade, howeverduring test bootunable to hold 5

PSI airpressure.

Replaced bootto no avail.

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No test boots, piping system will have to be taken off line andnew boots installed, if they will fit older design.

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No test boots, piping system will have to be taken off line andnew boots installed, if they will fit older design.

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Test boot left on. But in what condition? Will it work?

13Everything left on, however this system leak air around this boot.

Boot being replaced, however no guarantee system will pass.

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Old style sump, bolted to the tank manway. Gasket candeteriorate and allow small leakage's.

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Old style secondary containment. Not enough material to place aboot on for testing.

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Old style secondary containment. Not enough material to install atest boot on. Also not sealed to sump.

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UST Installed long distance frombuilding. Generator is on the roof.

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Pressuresystem to

push fuel upto the

Generator onthe roof.

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Piping secondarycontainment fromUnderground thruwall on its way to

the Roof.

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Side view

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Piping upthru deckon way tothe Roof.

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Piping going up outside wall to the Roof

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• The repair/corrective action to these types ofUST Systems is many times a complete tank topupgrade with new compatible materials at a costof $50,000 to $60,000.

• The minimum corrective action in many cases isreplace the supply and return piping systemand/or replacing the sump(s). This requirescutting concrete and replacing the manways ontop of the tank.

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• The population of Standby/Emergency GeneratorUST’s is equal to the number of petroleumindustry UST’s.

• However these UST’s pose a lot less risk. Mosthave suction systems and use diesel fuel.

• These UST’s are owned and operated by manyNon Petroleum Corporations who are not in thepetroleum business. These Generators/engineswith UST’s do not generate any revenue and arean expense against the bottom line.

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• Because these systems do not contribute to thebottom line they are classified (tax wise)differently. Many times a certain type of work ordollar amount requires that Capital Dollars usedand expensed.

• Obtaining Capital dollars expenditure for a nonprofit center is difficult at the best of times.

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• With the current recession the Xxxxxxxxxxxindustry has cut back its capital expenditures by20 %.

• At XXX All Capital Dollar expenditures must besubmitted as a business case to CapitalManagement, City, State. Capital projectsexceeding $2 Million Dollars require a longform Business Case be submitted and approvedby a Senior VP.

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• The long form Business Case requires a NetPresent Value Model be submitted. (fun)

• XXXX has 200 plus UST installed before 1992.And 300 Plus installed after 1992 that are beingSecondary Containment Tested with numeroustesting problems and dispenser pan installationon fleet vehicle refueling UST’s. XXX’sCalifornia cost is expected to reach over $16Million Dollars by the end of the program.

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• This is a major expense in such a short timeframe. More time is required to obtain capitaldollar approval and then time (drawing, permits,contractors availability, etc.) to completed therequired corrective actions for over 400 UST’s.

• Suggestion - UST Systems that are not testableand/or have some component fail secondarytesting be treated as single wall systems untilsuch time they can be brought into compliance.

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• Current Regulations (Section 2637(a)(1) Title23 Division 3 Chapter 16 CCR) allows for thereplacement of secondary containmentsystems with a system that can be tested byJuly 1, 2005.

• This is two and a half years after the Dec. 31,2002 deadline.

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• I would like to propose that UST Systemsinstalled before 1/1/2001 that are nottestable or have a secondary componentfailure be allowed to operate under Sec.2637(a)(1).

• The additional two and half years is very

valuable time that is required tosuccessfully complete this program.

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• I would like to Thank the Panel and the Boardfor their time today and ask that you take intoconsideration the conclusions of thispresentation.

• If you have any questions or need anyadditional information please contact me at 925823 6161. E-mail [email protected]

Documents

SB989 Secondary Containment Testing by Stan … SB989 Secondary Containment Testing by Stan Brodecki XXX Environmental Management Non Testable Secondary Containment Systems and When