Fairbanks Environmental Ltd

Notes for discussion with US EPA
Introduction

 96 UK staff 

 Introduced SIR systems into the UK in 1997

 56% of UK service stations now use SIR based 

centralised monitoring

 Now providing services to 4,500 gas stations

 2,000 gas stations use our ‘real time analysis service 

 Services being provided in 8 regions

(Australia , Japan, UK, Ireland, Turkey, Spain, Italy and 

France)
Our SIR method uses ‘peer group’ comparative analysis

Loss commenced here
Run 

Weekly 

SIR 

Analysis 

‘Conclusive’ 

results are 

maximised

Small Leak 

Investigation 

Opened

Owners 

Ibank alarms 

for Gauge, 

Line & Pump 

Data errors 

resolved 

with Site 

Manager

Sudden Loss 

Investigation 

Opened

DAILY WEEKLY 

Analysis and loss investigation process

Owners 

updated at 

every stage

Site Notes 

updated at 

every stage

Investigation 

concluded

Mgmt 

Reports 

produced

Wetstock 

data 

uploaded

Data tracked 

and ‘late 

data’ reports 

produced

Extreme 

Variances 

reviewed & 

resolved

Line & Pump 

issues 

investigated

DAILY 

TASKS

WEEKLY 

TASKS
Real time data collection

Site controller

Dispensers

ATG

Data acquisition 

module*

Confirmed 

tanker 

deliveries

Every 30 seconds

• Tank stock levels

• Water & temperature

• Alarms

POS Fairbanks Data Centre

* Or Softibank service running on site PC

Every fuelling transaction

• start time 

• finish time

• Volume 
What if you can pinpoint the cause of loss remotely
Over-dispensing 

Case Study 

 Pin points the pump

 Targeted contractor visits

 Quickly stops the loss
Line leak Case Study

ibank detects an unusual increase in stock 

level and flags it to the Analyst 

Period of no sales

Stock level drops as 

sales take place
Points for discussion

• Merits of increasing standard from 0.2gph to 0.1gph

• Performing SIR on a weekly basis ( on 30 days prior data) rather than monthly will identify a 

release up to 4 weeks sooner

• 3gph leak detection on pr 3gph leak detection on pressurised piping essurised piping can allow a significant can allow a significant release bef lease before detection detection –

• How is remote ( offset fill) piping protected

• Does CITLD only cover technologies embedded within an ATG or can this be extended to 

functionality located on a site PC or remote server

• Is CITLD intended to cover the entire system ( and not just tanks) in all cases
Points for discussion

• Suction systems with UPV’s fitted and lines draining back to the tank do not require any 

other release detection method ?

• Are all proposed methods deemed to provide the same level of protection or is there case for 

adopting the appropriate level of prevention/ detection commensurate with the ‘risk 

ranking’ of gas stations

• Are you familiar amiliar with the UK guidance with the UK guidance ( ‘The Blue Book’) The Blue Book’) which uses a risk based appr which uses a risk based approach.

• Concern over a high volume station using pressurised piping and single wall tanks in an area 

of high environmental sensitivity relying purely on ELLD at 3gph ? likelihood of an leak at a 

rate of 2.5gph continuing for a considerable period

• How to propose a real time analysis method which may not be included within the CITLD 

class .

• Open discussion.