1

Task Order 3003

– General Technical and Programmatic Support for Regulatory Development Technical Directive Number 9 Task 2, Subtask b

– Release Detection Research

Summary of Release Detection Research

May 27 , 2009 Background This report includes summaries of the following five research tasks related to release detection:

 The degree to which currently available release detection equipment can exceed federal UST performance requirements;
 Costs for equipment that meets or exceeds federal standards;
 State release detection requirements that are more stringent than federal requirements;
 Costs of interstitial monitoring; and,
 Costs for periodic integrity testing of the interstitial space for secondaril ycontained UST s ys tems. Eight appendices are included a s Excel worksheets:

 Appendix A: Release Detection Sy stem Capabilities
 Appendix B: Release Detection Performance and Cos ts  Appendix C: Summary of State Federal Language Incorporation
 Appendix D: Summarized State Regulation Compliance with Federal Regulatio ns  Appendix E: Additional State Regulations
 Appendix F: State Regulation Sources
 Appendix G: State Requirements
 Appendix H: Interstitial Monitoring Costs
 Appendix I : Integrity Testing Costs Release Detection Equipment Capabilities Analysis Methodology E 2 In c. analyzed the leak rate, probability of detection (Pd), and probability of false alarm (Pfa) capabilities for UST leak detection equipment included in the National Work Group on L eak Detection Evaluation’s (NWGLDE) publication “L ist of Leak Detection Evaluations for UST Sy stems” (L ist) 1 , 2 . Equipment capabilities , determined by third

party evaluation, were compared to federal performance requirements to identify equipment that is capable of exceeding federal standards. This anal ys is only includes

1 15 th edition, January 2008. 2 Use of the List is not an endorsement of included equipment.2

thos e release detection methods that have applicable data in the List. In order for equipment or procedures to be listed by NWGLDE, they

must, at a minimum, meet federal performance standards. E 2 In c. analyzed the performance capabilities of the 237 release detection devices and procedures for which the List includes leak rate, Pd, and Pfa. Anal ys is included the following leak detection methods:

 Automatic L ine Leak Detectors (ALLD): o Electronic Line Leak Detection (ELLD) o Mechanical Line Leak Detection (MLLD)
 Automatic Tank Gauging (ATG)
 UST System Testing o Line Testing
 Line Tightness Test Method o Tank Testing
 Non

- Volumetric Tank Tightness
 Tracer  Ullage
 Vacuum
 Volumetric Tank Tightness
 Overfill
 Underfill
 Other o Continu ous Automatic Tank Gauging (Continu ous ATG) o Continual Reconciliation o Qualitative Statistical Inventory Reconciliation (Qualitative SIR) o Quantitative Statistical Inventory Reconciliation (Quantitative SIR) The L ist does not include leak rates, Pd, or Pfa for 241 release detection devices and proced ures within the following release detection methods, which were therefore not included in the capabilities anal ys is:

 Interstitial Monitoring o Interstitial Detector (Liquid Phase) o Continuous Interstitial L ine Monitoring (Pressure/Vacuum)
 Groundwater Monitoring o Out

- of

- Tank Product Detector (Liquid

- Phase)
 Vapor Monitoring o Out

- of

- Tank Product Detector (Vapor

- Phase) Federal Standards The federal standards define the minimum performance requirements for release detection methods . Though all of the 237 release d etection equipment and procedures are subject to federal regulation, federal performance standards are specified for each detection method (Table 1). The 241 release detection devices or procedures not3

included in the capabilities anal ys is were not includ ed because the federal regulations do not identify

performance standards in terms of leak rate, Pd and Pfa for interstitial monitoring, ground water monitoring , or vapor monitoring.
Federal Performance Standards 3 Leak Detection Method Leak Rate

(gph) Pd (%) Pfa (%) ALLD 3.0 95 5 AT G 0.2 95 5 Tank Tightness 0.1 95 5 Line Tightness 0.1 95 5 SIR 0.2 95 5 Table 1. Federal performance standards for release detection. Results Distribution of Release Detection Methods The NWGLDE List includes leak rate , Pd, and Pfa for 13 release detection methods. These methods fall into four primary categories: Automatic Line Leak Detection (ALLD), Automatic Tank Gauging (ATG), Tightness Testing (TT), and Other. These four categories include 237 devices and test pro cedures.

Release Detection Methods Number of Release Detection Devices/Procedures Subtotal Total Percent Automatic Line Leak Detection Electronic 34

- 52 22 Mechanical 18

- Automatic Tank Gauging 82

- 82 35
Tightness Testing Line Tightness Tank Method 10

-
59 25

Tank Tightness Method Non

Volumetric Tracer 1 32

Ullage 5 Vacuum 26 Volumetric Overfill 15 17

Underfill 2
Other Continuous ATG 13

- 44 19

Continual Reconciliation 6 Qualitative SIR 13 Quantitativ e SIR 12

Total 237

- 237 101.00 Table 2. Distribution of release detection methods with leak rate, Pd, and Pfa included in the List. Note: The final total for the “Percent” column is greater than 100 percent due to rounding. There are 52 devices for the ALLD method, representing 22 percent of all anal yz ed methods. Automatic tank gauging includes 82 listed devices , comprising 35 percent of all anal yz ed methods. Li ne and tank tightness methods include 59 procedures,

3 From 40 CFR 280.43 and 280.44.4

comprising 25 percent of all anal y zed methods. The Other category includes 44 devices and procedure s representing 19 percent of the analyzed leak detection methods. Release Detection Methods Exceeding Federal Regulatory Performance Standards Review of the 13 release detection methods that are included in the List did not reveal any equipment or procedure that failed to meet federal regulatory performance requirements. Table 3 summarizes release detection equipment and procedures capable of exceeding federal performance requirements.

a. Electronic Line Leak Detection Analy sis determined that 94 percent of the reviewed ELLD devices are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed ELLD devices are capable of exceeding the federal performance requirements for Pd and Pfa. b. Mechanical Line Leak Detection Analy sis determined that none of the reviewed MLLD options are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed ML LD options are capable of exceeding the federal performance requirements for Pd and Pfa.

c. Automatic Tank Gauging Analy sis determined that 44 percent of the reviewed ATG s ys tems are capable of exceeding the federal performance requirements for leak rate. N inety- four percent are capable of exceeding Pd requirements and 96 percent are capable of exceeding Pfa requirements. Of the ATGs capable of exceeding the federal leak rate requirement, 93 percent can exceed Pd and Pfa requirements. Forty

- five percent of ATGs capable of exceeding federal Pd standards and 44 percent of ATGs capable of exceeding federal Pfa standards are also capable of exceeding federal leak rate standards. Ninety - seven percent of ATGs capable of exceeding federal Pd standards are also ca pable of exceeding federal Pfa standards. d. Line Tightness Analy sis determined that none of the reviewed Line Tightness procedures are capable of exceeding the federal performance requirements for leak rate. Ninety percent of the reviewed Li ne Tightness procedures are capable of exceeding the federal performance requirements for Pd and Pfa.

e. Tracer Method Analy sis determined that none of the reviewed Tracer test procedures are listed by NWGLDE as exceeding the federal performance requirements for leak rat e. One hundred percent of the reviewed Tracer test procedures are capable of exceeding the federal performance requirements for Pd and Pfa. f. Ullage Test Method5

Analy sis determined that 40 percent of the reviewed Ullage test procedures are capable of excee ding the federal performance requirements for leak rate. One hundred percent of the reviewed Ullage tests are capable of exceeding the federal performance requirements for Pd and Pfa. g. Vacuum Test Method Analy sis determined that 73 percent of the reviewed Vacuum test procedures are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed Vacuum tests are capable of exceeding the federal performance requirements for Pd and Pfa. h. Overfill Test Method Analy sis determined that seven percent of the reviewed Overfill test procedures are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed Overfill tests are capable of exceeding the federal performance requirements for Pd and Pfa. i. Underfill Test Method Analy sis determined that 100 percent of the reviewed Underfill test procedures are capable of exceeding the federal performance requirements for leak rate, Pd, and Pfa. j. Continuous ATG Analy sis determined th at none of the reviewed Continuous ATGs are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed Continuous ATGs are capable of exceeding the federal performance requirements for Pd and Pfa. k. Continu al Reconciliation Analy sis determined that none of the reviewed Continual Reconciliation procedures are capable of exceeding the federal performance requirements for leak rate. One hundred percent of the reviewed Continual Reconciliation procedures are ca pable of exceeding the federal performance requirements for Pd and Pfa. l. Qualitative SIR Analy sis determined that eight percent of the reviewed Qualitative SIR methods are capable of exceeding the federal performance requirements for leak rate. Ninety

- two percent of the reviewed Qualitative SIR methods are capable of exceeding the federal performance requirements for Pd and Pfa.

m. Quantitative SIR Analy sis determined that none of the reviewed Quantitative SIR methods are capable of exceeding the federal per formance requirements for leak rate. One hundred percent of the reviewed Quantitative SIR methods are capable of exceeding the federal performance requirements for Pd and Pfa

.6 Detection Method Number of Options Exceed Federal

Leak Rate Regulations Excee d Federal

Pd Regulations Exceed Federal

Pfa Regulations Count Percent Count Percent Count Percent ALLD ELLD 34 32 94.12 34 100.00 34 100.00

MLLD 18 0 0.00 18 100.00 18 100.00 AT G AT G 82 36 43.90 77 93.90 79 96.34

Tightness Testing Line

Testing Line Tightness Test

Method 10 0 0.00 9 90.00 9 90.00

Tank Testing Non

Volumetric Tank Tightness Tracer 1 0 0.00 1 100.00 1 100.00

Ullage 5 2 40.00 5 100.00 5 100.00 Vacuum 26 19 73.08 26 100.00 26 100.00 Volumetric Tank Tightness Overfill 15 1 6.6 7 15 100.00 15 100.00

Underfill 2 2 100.00 2 100.00 2 100.00

Other Continuous ATG 13 0 0.00 13 100.00 13 100.00

Continual Reconciliation 6 0 0.00 6 100.00 6 100.00 Qualitative SIR 13 1 7.69 12 92.31 12 92.31 Quantitative SIR 12 0 0.00 12 100.00 12 100.00

Totals 237 93 39.24 230 97.05 232 97.89 Table 3. Release detection methods capable of exceeding federal performance standards. Costs of Equipment Meeting or Exceeding Federal Requirements Methodology Costs of equipment in the NWGLDE List wer e researched using Internet sources and b y contacting not more than nine distributors of UST leak detection equipment4 . Equipment distributors were located by searching online industry directories and through general Internet searches. Company Web sites were reviewed to confirm that the company sold leak detection equipment listed by the NWGLDE and to determine if associated prices were available online. None of the nine companies that were interviewed provide equipment prices online. Interviewed distributors were first contacted with a phone call to discuss the availability of equipment prices. During phone conversations all nine contacts agreed to review a spreadsheet of leak detection equipment e

- mailed by E 2 Inc. and to provide cost estimates if p ossible. Due to the size of the information request, distributors were asked to provide any relevant information and it was suggested that they provide at least one price quote for each leak detection method. Vendors were contacted on multiple occasions to inquire about the status of the cost estimates. Table 4 lists the contacted distributors.

4 In order to comply with the Paperwork Reduction Act, no more than nine contractors were contacted.7 Company State EPA Region Status Franklin Equipment Services, Inc. NY 2 Declined to participate Glasgow Equipment FL 4 Declined to participate Jones & Frank Corporation NC 4 Received Southern Pump Company NC 4 Not received Source North America Corporation IL 5 Not received OES Corporation IN 5 Declined to participate PSI Equipment Sales CA 9 Not received Shields Harper CA 9 Declined to participate Northwest Pump & Equipment OR 10 Not received Table 4. The nine vendors interviewed for leak detection equipment costs. State column denotes the location of branch contacted. Results Of the nine equipment distributors contacted, four officiall y decline d to participate, primarily citing time constraints. Four distributors neither declined to participate nor provided data. One distributor provided cost information in the form of manufacturers’ price lists. Received manufacturer catalogs included:

 Franklin Fueling S ys tems/Incon (August 2008)
 OMNTEC Mfg., Inc. (October 2008)
 OPW Fuel Management Sy stems (January 2009)
 Pneumercator Inc. (January 2007)
 Robertshaw Industrial Products (November 2008)
 Veeder

- Root Company (September 2008) Prices for NWGLDE

- lis ted equipment were identified from these catalogs and combined to determine total equipment costs. For example, costs of the console, interface module, probe, and float kit were totaled to reflect the total equipment cost associated with listed ATGs. Required parts were identified through manufacturer catalogs and Web sites. In addition to manufacturer catalogs, Internet research yi elded equipment costs from online distributors. For equipment listed in multiple sources, average prices were calculated. For example, prices for the Veeder

- Root TL S

- 350 console were found in the manufacturer catalog and two distributor Web sites. Average costs were also used for NWGLDE

- listed sy stems that include interchangeable devices (e.g., listings including multiple consoles). Costs and performance capabilities are listed in Appendix B. Unless otherwise noted, prices are for a single line or tank. Costs of 9 3 NWGLDE

- listed equipment and procedures were obtained through interviews and online research (Appendix B)

. Of these 9 3 devices and procedures , 4 0 included federal leak rate, Pd, and Pfa standards (Table 5)

. T he remaining 53 devices and procedures do not have leak rate, Pd, or Pfa listed by the NWGLDE. Of the equipment and procedure options for which costs, leak rate, Pd, and Pfa were obtained, all 4 0 exceed their respective federal Pd and Pfa.8 Detection Method Number of NWGDLE

listed Options Number of

Cost Estimates Obtained Percent

of Listed Options Average Cost ALLD ELLD 34 6 17.65 $ 815

MLLD 18 7 38 .89 $2 48 AT G AT G 82 12 14.63 $ 3,451

Tightness Testing Line

Testing Line Tightness Test

Method 10 4 4 0 $13 0 per line

Tank Testing Non

Volumetric Tank Tightness Tracer 1 0 0 D ata not available (DNA) Ullage 5 1 20 $500 Vacuum 26 2 7.69 $ 538 5 Vo lumetric Tank Tightness Overfill 15 1 6.67 $900 5

Underfill 2 1 50 $1,085 5

Other Continuous ATG 13 5 38.46 $4,254

Continual Reconciliation 6 0 0 DNA Q ualitative SIR 13 0 0 DNA Quantitative SIR 12 1 8.33 $50 per month

Totals 237 4 0 1 6.88 Table 5. Cost s for release detection methods that are evaluated to meet federal performance standards. Within the ten leak detection methods for which cost information was obtained, no notable price differences were found between equipment or procedures that meet federal leak detection standards and those that exceed federal standards. All ELLD and MLLD equipment options for which cost information was obtained are capable of exceeding federal leak rate performance standards. Prices were obtained for 12 ATG sy stems; eight of these ATGs exceed the federal leak rate standard and four meet the federal leak rate standard. The average cost of these four ATGs was determi ned to be $124 less than the eight that exceed the federal leak rate standard. All equipment for the other eight leak detection methods for which cost information was obtained are capable of meeting, but not exceeding, federal leak rate performance standards. The data provided may

not be representative of average costs due to the small sample size. Costs of only 1 6

. 88 percent of release detection equipment and procedures with performance standards were obtained , the majority of which are within four re lease detection methods: ELLD, MLLD, ATG, and Continuous ATG

.

5 Costs are per tank at a single

- tank site.9

State Release Detection Requirements Methodology E 2 In c. researched UST release detection regulations for 56 states and territories. State and territory

release detection requirements were compared with federal leak rate, Pd, and Pfa standards as stated in the following sections of 40 C.F.R. 280:

 § 280.40 General requirements for UST sy stems  § 280.43 Methods of release detection for tanks a. Inventory

control b. Manual tank gauging c. Tank tightn ess testing d. Automatic tank gauging e. Vapor monitoring f. Ground

- water monitoring g. Interstitial monitoring h. Other methods
 § 280.44 Methods of release detection for piping a. Automatic line leak detectors b. Line tightness testing c. Applicable tank methods Each applicable state and territory rule was classified as having incorporated federal regulations, either through adoption by reference or by

using language to the same effect as the federal regulation text, or as having more stringent requirements than the federal rule s (Appendix C). State compliance with the release detection leak rates set forth in 40 C.F.R. 280 is found in Appendix D. Additional state and territory regulations are presented in Appendix E and sources of state regulatory information are listed in Appendix F. Appendix G lists state rules for each release detection method. Results States That Enforce Federal Regulations Twelve of the 56 states and territories have incorporated the federal UST regulations b y reference (Arkansas, Commonwealth of Northern Mariana Islands, Georgia, Idaho, Kansas, Kentucky, Michigan, Nevada, North Carolina, U.S. Virgin Islands, Utah, and West Virginia) . An additional eight states and one territory have adopted language identical or significantl y similar to federal UST regulations , including the same leak rates for each leak detection method (Indiana, Iowa, Mississippi, New Jersey , New Mexico, North Dakota, Puerto Rico, South Carolina, and Virginia) . Regulations for two territories, Guam and American Samoa, mention rele ase detection methods but do not specify leak rates and do not indicate adoption of federal requirements. The remaining10

34 states and territories modified the federal requirements, in most cases to more stringent terms and/or b y the addition of tests not specified in the federal requirements. States with More Stringent Regulations § 280.43 Methods of release detection for tanks a. Product inventory control Five states specify

more stringent leak rates for product inventory control than the federal ly requ ire d monthly check to detect a release of at least 1.0 percent of flow

through plus 130 gallons (Table 6).

State Leak Rate Maine 0.1 gph Maryland 0.2 gph, or 150 gallons per month Massachusetts 0.5% of volume of product dispensed over a period of a

c alendar month New York 0.75% of tank volume, or losses or gains exceeding 7.5

gallons per 1,000 gallons delivered Wisconsin 0.5%, or 5 gallons out of every 1,000 gallons of throughput Table 6: S tate product inventory control leak rates that are mo re stringent than the federal requirements. Gallons

- per - hour is indicated as “gph.” Rule §280.43(a)(4) states that deliveries to USTs must be made through a drop tube that extends to within one foot of the tank bottom. Several states (I llinois, Michigan, Okl ahoma, and Wyoming) have changed this rule to have the drop tube extend to within six inches of the tank bottom, and Delaware has changed the distance to 5.9 inches. Several states indicate that product inventory control may

not be used as a sole leak det ection method (e.g., Arizona, Oregon, and Wyoming). Some states have allowed a ten
- ye ar grace period after USTs achieve compliance with corrosion protection requirements before product inventory control is no longer acceptable as a primary release detecti on method. I llinois disallowed new sites to utilize inventory control as a primary release detection method after May 1, 2003, and Oregon disallowed it at all sites after December 22, 2008. b. Manual tank gauging Sixteen states altered Rule §280.43(b)(5 ) to allow manual tank gauging as the sole method of leak detection for tanks larger than the 550 gallon nominal maximum defined in the federal regulations (Alaska, California, Colorado, Hawaii, Illinois, Minnesota, Missouri, Nebraska, Oklahoma, Oregon, So uth Dakota, Tennessee, Texas, Washington, Wisconsin, and Wyoming) . Sixteen states added more stringent leak rates for tanks of 551

- 1,000 gallon capacity based on the tank diameter ( Table 7 ; Alaska, California, Colorado, Delaware, Florida, Hawaii, Minnesot a, Missouri, Nebraska, Oklahoma, Pennsylvania, South Dakota, Tennessee, Texas, Wisconsin, and Wyoming)

.11 Tank Capacity Diam eter Weekly Standard Monthly Standard 551

- 1,000 gallons 48 inches 12 gallons 6 gallons 551

- 1,000 gallons 64 inches 9 gallons 4 g allons 551

- 1,000 gallons Not specified 13 gallons 7 gallons Table 7: More stringent manual tank gauging release detection leak rates based on tank diameter for USTs with a capacity of 551

- 1,000 gallons. The last row with unspecified diameter is the fede ral standard. Massachusetts changed the weekl y standard release detection leak rate for tanks 1,001

- 2,000 gallons from 26 gallons to 25 gallons when using manual tank gauging (MTG). Illinois changed the rule to apply for tanks of 600 gallon capacity or l ess. Washington state regulations allow for MTG as the sole method of release detection for emergency power generator tanks of 2,000 gallon capacity or greater. The release detection leak rate for such tanks is 0.75 percent weekly standard and 0.5 percent monthl y standard. Illinois specifies that tanks that have been upgraded using the cathodic protection method cannot use MTG as a method of release detection and that after May 1, 2003, only

tanks of 600 gallon capacity

or less, unless within the 10

- ye ar post cathodic protection installation allowance, could utilize MTG for release detection. In California, no tanks with secondary

containment or capacity greater than 1,000 gallons could use this method after December 22, 1998. California also increased the minimum time out of service from 36 to 48 hours when utilizing MTG. Oregon has disallowed use of MTG as a primary release detection method after December 22, 2008. c. Tank tightness testing New York has a more stringent rate of 0.05 gph, and Maryland has leak rates set in accordance with tank capacity , varying from 0.05 gph (0

- 12,500 gallon capacity tank) to 0.150 gph (47,501 gallon capacity or greater). Tank tightness testing was disallowed as a primary method of release detection in Delaware afte r December 31, 2008. d. Automatic tank gauging The majority

of states and territories require the same ATG leak rate of 0.2 gph stated in Rule §280.43(d)(1). Both Oklahoma and California require a 0.1 gph leak rate to be detected using ATG in conjuncti on with monthly inventory

reconciliation. Delaware also requires a 0.1 gph monthly release detection leak rate for ATG. e. Vapor monitoring Vapor monitoring is currently not, or is scheduled to no longer be, an approved method of release prevention in V ermont and Delaware and is not allowed as the sole release detection method in Ohio and Wyoming. California includes site

- specific restrictions on use of vapor monitoring and New Hampshire does not allow vapor monitoring in tanks without secondary

containment and leak monitoring. Alaska, Massachusetts, Michigan, and Oregon only allow use of vapor monitoring as release detection with prior approval b y fire departments and require more stringent measures as deemed necessary on a site

- by

- site basis. New York onl y allows vapor monitoring wells at uncontaminated sites.12

Florida and Oklahoma require vapor monitoring release detection to be capable of detecting a 500 parts per million (ppm) increase over background or historical levels. Florida has a 500 ppm le ak rate for tanks containing gasoline or equivalent petroleum substances and a 50 ppm leak rate for tanks containing kerosene or diesel. Oklahoma has less stringent leak rates of 4,000 ppm for gasoline and 1,500 ppm for diesel. Rule §280.43(e)(3) states that site

- specific conditions will not allow for a leak to go undetected for more than 30 day s. The District of Columbia has reduced this time to a maximum of 15 days, North Carolina further reduced it to 14 days, and Delaware omitted a time when a leak c ould go detected altogether, thereby suggesting that a leak should be detected immediatel y regardless of site conditions. f. Ground water monitoring The release detection leak rate indicated in Rule §280.43(f)(6) is 1/8 of an inch free product on top of ground water. New York has changed this to be more stringent at 1/64 of an inch of free product on the ground water surface. Eight states do not allow, or are phasing out, the use of ground water monitoring as a form or release prevention (Alaska, Flo rida, Massachusetts, Michigan, New Hampshire, Ohio, Rhode I sland, and Texas) . New Hampshire does not allow ground water monitoring as the primary release detection method for tanks without secondary containment and leak monitoring. In Florida, when produ ct is detected in a ground water mo nitoring well the well to be clear of contamination for 30 consecutive months prior to allowing ground water monitoring to be reinstated as a site’s release detection method. Alaska, Minnesota, and Oregon require p rior a pproval of the ground water monitoring method by

the fire department. g. Interstitial monitoring Florida has set the release detection leak rate as 0.2 gph and Maine has set the leak rate at 150 gallons or more within 30 day s. For USTs using vacuum moni toring, The District of Columbia considers a leak to be indicated if the vacuum falls below five inches of mercury , whereas Vermont and Florida consider any gain or loss in vacuum or pressure to be indicative of a leak. Continuous monitoring to detect wat er, regulated substance, and/or regulated substance vapors is required in New Hampshire and Rhode Island. Georgia and Maine require secondary containment and interstitial monitoring for all new or replaced USTs and associated piping. h. Other methods The majority

of states and territories incorporated rule §280.43(h)(1), with the exceptions of New Hampshire, New York, Rhode Island, and Vermont, which do not permit methods other than those specificall y listed in their Administrative Codes. California, Flo rida, Massachusetts, Oklahoma , and Wisconsin also do not permit release detection methods not listed in their Codes, but these five states do specifically include statistical inventory reconciliation as an acceptable "other" release detection method.13

§ 280.44 Methods of release detection for piping a. Automatic line leak detectors All states and territories included the federal rule §280.44(a) for an automatic line leak detection rate of 3.0 gph at 10 pounds per square inch (psi) within one hour. Maine requires continuous line leak detection monitoring for all piping sumps including dispenser pumps and pans. b. Line tightness testing All states and territories except New York included the federal rule §280.44(b) leak rate of 0.1 gph at one and one

- half times the operating pressure. New York had a more stringent leak rate of 0.05 gph. Michigan requires that secondary containment piping shall be tested at 5 psi for the minimum time of one hour. c. Applicable tank methods Thirty

- nine states and territories included language from rule §280.44(c) stating that applicable tank methods could be used as a release detection method for piping. Th is language was omitted from the remaining 14 states for which information was found ( C alifornia , D elaware , F lorida , Maine, M assachusetts , New Hampshire , New York, Ohio , Oklahoma , Oregon , Rhode Island , South Dakota , Vermont , and Wisconsin)

. Additional tests beyond federal requirements Seventeen states include statistical inventory reconciliation (SIR) in their regulati ons as an acceptable release detection method (Alaska, California, Connecticut, Florida, Illinois, Louisiana, Maine, Maryland, Massachusetts, Oklahoma, Oregon, Penns yl vania, Tennessee, Texas, Washington, Wisconsin, and Wyoming )

. Eleven of these states use the federal release detection leak rate from §280.43(h)(1) “Other methods” of 0.2 gph or a release of 150 gallons within a month. The exceptions are listed in Table 8:

State Release detection leak rate Connecticut "abnormal loss or gain which is not explainable by spillage, tem perature variations or other known causes" Maine 0.1 gph Massachusetts "statistically significant loss" Oklahoma None specified Pennsylvania absolute value of calculated leak rate exceeds leak threshold Table 8: State release detection leak rates for USTs being monitored with statistical inventory reconciliation. These values differ from the federal leak rate for “Other methods” of release detection, which are 0.2 gph or 150 gallons within a month. Illinois currently

allows SIR as a release detection method but is discontinuing its use. No new requests to use the method will be accepted after the May 1, 2003 cut

- off date, and sites where the method has been interrupted may not resume its use. Statistical inventory reconcili ation has been banned from use on sy stems with blending pumps or siphon tanks, effective in I llinois after January 1, 2006. Wyoming also lists the use of tracer survey s and passive acoustical sensing as acceptable “Other methods” of release detection in the state, provided that they can detect a leak rate14

to comply

at minimum with the 0.2 gph or 150 gallons per month rate in the federal regulation. California state regulations require visual inspection of all visible exterior surfaces of an UST to be co nducted at least daily . Additionally , single

- walled tanks that are located within 1,000 feet of a public drinking water well must implement enhanced leak detection testing, capable of detecting a leak rate of at least 0.005 gph. California additionally m andates soil sampling in association with boring observation wells for vapors and/or ground water. Soil samples must be collected at five foot intervals, including ground surface and termination depth, and then analyzed in a state

- certified laboratory for one or more of the most persistent constituents that have been stored in the UST. In Connecticut, UST facilities that did not have release detection equipment when the state regulations became effective in 1994 must use failure determination testing until one of the federall y listed release detection methods is in place. Costs of Interstitial Monitoring Methodology E 2 In c. used EPA and industry Web sites and the NWGLDE List to identify applicable methods of interstitial monitoring. Identified methods include:
 Pressure  Vacuum  Liquid

- filled
 Automatic Tank Gauge (with liquid point sensor in interstice) Costs of these interstitial monitoring methods were researched using Internet sources and by contacting not more than nine contractors (Table 9 ). Contrac tors were identified through online industry

directories, state UST Web sites, and general Internet searches. Company Web sites were reviewed to determine if they installed and monitored interstitial monitoring systems and if associated costs were availab le online. Additional cost estimates were obtained from a November 2007 Affidavit by Charles Frey , Vice President of Highland Tank and Manufacturing Company , Inc and board member of the Steel Tank Institute. Selected contractors were first contacted with a phone call to discuss the availability of cost estimates. During phone conversations all nine contacts agreed to review a spreadsheet of interstitial monitoring methods e

- mailed by E 2 Inc. and provide cost estimates for interstitial monitoring equipment, installation, operation and maintenance, and monitoring and testing, if possible.15 Contractor State EPA Region Status Valley Equipment Company NY 2 Declined to participate Crom pCo , LLC PA 3 Received Mid Valley Supply KY 4 Not received Minnesota Petroleum MN 5 Received US Tank Alliance OH 5 Declined to participate PetroServ Inc TX 6 Not received Tanknology MD 6 Received Petro West Inc. UT 8 Not received Service Station Systems, Inc. CA 9 Received Table 9 . Contractors contacted for intersti tial monitoring and integrity test cost estimates. The s tate column denotes the location of branch contacted. Results Of the nine contractors contacted, four provided estimates for costs associated with interstitial monitoring systems (Table 10) . Two of the remaining five contractors officiall y declined to participate. All estimates are for a three tank site with the conduit already in place. The purchase cost for vacuum sy stems were an estimated $549 less than liquid

- filled sy stems. The c ombined p urchase and installation costs of liquid

- filled sy stems were on average $ 9 44 dollars more than ATG s ys tems with liquid point sensors. Costs for purchase and installation of pressure

- based sy stems were not obtained. The se data may not be representative of average costs due to the small sample size.
Type of Interstitial Monitoring Average Estim ated Costs 6

Purchase Installation Annual Operation and Maintenance Annual

Monitoring and Testing Pressure DNA DNA DNA $488 Vacuum $ 10,191 DNA DNA $488 Liquid

- f illed $10,740 DNA $500 7

$12,000 8
AT G (with liquid point sensor) $11,056 8 $500 7 DNA $300 Table 10 . Average estimated costs for interstitial monitoring. DNA denotes data not available. One contractor estimated annual monitoring and testing costs for pressure and vacuum interstitial monitoring systems as $488 for a three tank site. One contractor estimated

6 All estimates are for a three tank site with the conduit already in place. 7 Contractor did not distinguish operation and maintenance and monitoring and testing costs. 8 Contractor did not distinguish purchase and installation costs.16

annual monitoring and testing costs of periodic ATGs as $300. Another contractor did not distinguish between annual operation and maintenance costs and annual monitoring and testing costs for ATG sy stems and estimated the combined annual cost as $500. The se data may

not be representative of average costs due to the small sample size. Periodic Integrity Testing of Interstitial Space Methodo logy E 2 In c. first determined appropriate integrity test methods under the scope of work. Id entified integrity test methods include hydrostatic, vacuum, and pressure. These tests are applied to secondarily

- contained UST s ys tems, including:
 Tanks ,  Piping ,  Tank top sumps ,  Dispenser pans , and
 Spill buckets Costs of methods for testing integrity of secondarily

- contained UST components were researched using Internet sources and b y contacting not more than nine contractors. Contractor Web sites were reviewed to confirm whether they installed and monitored interstitial monitoring systems and if cost estimates were available online. The same nine contractors were interviewed as for the interstitial monitoring costs (see Table 9 ). Contractors were first contac ted with a phone call to discuss the availability of cost estimates. During phone conversations all nine contacts agreed to review a spreadsheet of integrity

test methods e

- mailed b y E 2 Inc. and provide associated cost estimates, if possible. Results O f the nine contractors contacted, two provided estimates for the cost of integrity testing of secondarily

- contained sy stems (Table 11 ). The data provided may not be representative of average costs due to the small sample size.
UST Component Test Method CrompCo , LLC Cost s Tanknology Costs Tank Hydrostatic DNA DNA

Pressure/Vacuum $150 per tank $125 per tank Piping Hydrostatic DNA DNA

Pressure/Vacuum $100 per line $125 per line Tank top sumps Hydrostatic $700 per site DNA

Pressure/Vacuum $700 per site DNA Dispenser Pans Hydrostatic $300 per site $150 per dispenser pan or sump Pressure/Vacuum $300 per site DNA17 UST Component Test Method CrompCo , LLC Cost s Tanknology Costs Spill Buckets Hydrostatic $600 per site $50 per spill bucket; $100 per site for wa ste fluid disposal Pressure/Vacuum $600 per site $50 per spill bucket Table 11 . Cost estimates for integrity testing of secondarily contained components. Average costs of interstitial integrity t est s are $137.50 per tank and $112.50 per line for piping. Costs of testing tank top sumps were estimated by one contractor as $700 per site. Costs for testing dispenser pans were reported as $300 per site or $150 per dispenser pan or sump. Testing costs for spill buckets were estimated as $600 per site or $50 per spill bucket. One contractor reported that th e h ydrostatic test for spill buckets includes an additional $100 for disposal of waste water. Cost saving opportunities Interviewed contractors reported that cost

- saving opportunities are possible, but that they occur on a site

- by

- site basis. Although no discount was reported for testing multiple sy stems at a site, a discount of $150 was reported for combining environmental testing with air testing. Additional o nline research found one UST contractor’s Web site that advertised a 10 percent discount if the tank owner booked testing services for the following ye ar.