Wisconsin Department of Commerce Newsletter
April 2005
ERS Division Represented at National EPA UST/LUST Conference

Wisconsin was well represented on the conference presentation agenda with two ERS staff participating as presenters during the three-day National Environmental Protection Agency's (EPA) Underground Storage Tank/Leaky Underground Storage Tank (UST/LUST) conference. James Moser, PECFA Grant Reviewer, was one of three presenters participating in the Policy Direction/Program Management track session on Paying for Cleanups. Moser's presentation focused on the roll of financial responsibility, and specifically Wisconsin experiences.

Sheldon Schall, Storage Tank Regulation Section Chief, conducted an overview of Wisconsin's data collection process for tracking the EPA mandated Significant Operational Compliance (SOC) measures. Tracking SOC is a new state-reporting requirement implemented by the EPA. Schall served on a national US EPA workgroup formed by the EPA as an advisory resource as the EPA developed the measures.

Other information presented at the conference included:
The STI (Steel Tank Institute) presented a study evaluating the source of water entry into USTs (underground storage tanks).

#1 Infiltration around fill pipe from loose fittings and water filled spill buckets
#2 Vent piping below grade
#3 STP sump device (or no device)
#4 Automatic tank gauge (ATG) probe fittings
#5 Missing or damaged caps
Condensation was mentioned, but not one of the major sources.

Bacteria's are becoming more of a problem in both fuel and tank degradation. The bacterium colonizes very quickly, which is enhanced by water. This particular bacteria lives in water, feeds on oil and produces a biologically active sludge that can corrode steel and clog motor vehicle fuel systems. Corrosion or pitting on the interior tank wall above the sludge line is not from bacteria.

The materials and configuration of spill buckets lend a useful life of only five to eight years so most of the spill buckets installed as a result of the federal rule requirement are at the end of their life. South Caroline checked 910 of the 1,032 spill buckets statewide and 77 or eight point four percent (8.4%) had failures that would allow product to escape into the ground around the bucket.

California conducted a study of the performance in relation to the EPA 95/5 criteria of various leak detection devices in operating systems.

  • Eighty one percent (81%) of ATGs performed within the criteria. The less than desired performance rates increased as the tank size increased. The results were: ninety five percent (95%) of the ATGs in tanks less than 8K, eighty four percent (84%) of ATGs in tanks 8-20K, and sixty three percent (63%) of ATGs in tanks greater than 20K. They also found that the performance rate decreased as the level of product decreased.
  • The mechanical line leak detector performance was quite disappointing with sixty three percent (63%) detecting 3 gph, and twelve percent (12%) each for 3-5 gph, 5-10 gph, and no detection. Mechanical line leak detection performance is significantly impacted by pipe length (> 111 feet)
  • The electronic line leak detection performance was seventy one percent (71%) at 3 gph, seventy percent (70%) at 0.2gph, and eighty percent (80%) at 0.1 gph; the last two with much poorer performance in flex pipe. Electronic line leak detection actually performs better in pipe length >111 feet than in shorter lengths of pipe. The failures appear to be associated with installation and programming issues.

South Carolina performed a study to assess the performance of UST system cathodic protection. They performed tests on 736 impressed current systems and 495 galvanic systems. Sixty six percent (66%) of the impressed current and forty eight percent (48%) of the galvanic systems were not adequately protecting the tank systems from corrosion. South Carolina then began to review system cathodic protection contractor testing data and found "a lot of weird data associated with a 'PASS."

California continues to implement new and more restrictive storage tank regulations, but their ongoing system assessment tests have reflected many interesting facts. First, they have pointed out that the existing leak detection methods are not foolproof and do not address vapor release that are now being recognized as major contributors to pollution.

California is performing much leak detection equipment assessment using leak detection via tracer type testing. Their focus on vapor releases is driven by the fact that a breach in a system equal to a 0.1 gph (gallon per hour) fluid test releases 6,000 pounds of gasoline each year as vapor (a vapor release equal to 0.005 gph fluid test equals 300 pounds gasoline or 44 gallons each year). What they have discovered as common vapor release problems in descending order of frequency is:

  • ATG assess riser and signal cable penetrations
  • Spill bucket drains
  • Inadequate seal of rings, gaskets joints, etc.
  • Thread fittings
  • Bruised or crimped piping
  • Flax connectors
  • Shear valves
    Spill bucket connections and drain valve

The conference is an annual event that brings representatives of the state UST and LUST regulatory programs together with EPA officials. The objectives include the rollout of EPA initiatives, state/EPA networking, state program feedback to the EPA, lessons learned workshops, and educational seminars.

- Berni Mattsson

The newsletter is issued electronically every other month.

Please send comments or questions to Barbro McGinn, editor.

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