DLA Energy

Response to EPA - Release Detection Point Paper

Pursuant to the last meeting where you advised us that you were closer to the decision to remove the 

deferral of release detection for Airport Hydrant Fuel Distribution Systems and Field Constructed USTs

and provided to us the Draft Deliberative Documents related to each, we have developed a brief 

response for your consideration.

Our overarching response to the removal of the deferral and your proposed release detection 

requirements is one of great concern. We believe these performance requirements will have a gross 

cost impact, possibly increasing the required budget by 400%. 

In addition, in order to facilitate execution of your proposed regulatory required actions, we expect the 

overall mission to be impacted by frequent “system shutdowns”. Also, the ability to conduct the 

proposed frequent testing will be severely limited by installation staff responsible for maintenance and 

operations and their availability. In addition, for those installations that are government owned and 

contractor operated, numerous contract modifications will be required to support this new 

requirement. 

Further, due to release detection technology requirements, we expect significant infrastructure 

modifications and changes will be required to enable test method application. Some of these actions 

may require Military Construction (MILCON) funding, projects that require Congressional approval with 

five year advance planning, which could significantly delay the Department of Defense’s (DoD’s) ability 

to be compliant. 

As you can see, your proposed path forward will have a cascading negative impact. However, we are in 

agreement that we jointly should continue to seek solutions that will support the protection of the 

environment, take into consideration the funding process and requirements, while allowing the critical 

mission to proceed. As you know, we “walk the walk” on this as evident by our current Leak Detection 

Program best management plan to perform release detection even when not required by regulation.

The following are specific comments and recommendations on the draft deliberative documents 

provided.

COMMENTS ON DRAFT DELIBERATIVE DOCUMENT – AIRPORT HYDRANT FUEL DISTRIBUTION SYSTEMS

Introduction Comments

With regards to the applicability to piping using diameter (you propose in your draft deliberative 

document that > to 6 inches, new requirements apply; <6 inches, current piping requirements apply), it 

is not possible to separate out and conduct different testing by diameter. Military airport hydrant 

systems are very complex with various diameters ranging from 4 to 20 inches. Piping with different 
diameters may not be able to be isolated and tested separately. We strongly recommend that any new 

requirements be developed for and apply to what ultimately is the definition of an airport hydrant 

system, irrespective of diameter. Thus, we disagree with your proposed approach to apply current 

release detection requirements to hydrant piping <6 inches in diameter.

1. Line Leak Detector: With regards to line leak detector requirements for Airport Hydrant Fuel 

Distribution Systems, we believe any regulation put forward should be based on the current availability 

of technologies able to meet the regulation, not on driving research and development. As technology 

becomes available, regulations could be updated accordingly.

2. RD Methods/Precision Test Annually to 1.0 gallon per hour (gph): The sensitivity and frequency 

requirement in this section should be greater than proposed in 4.

3. Not sure this section is relevant or would apply to military hydrant systems.

4. Performing Testing: Taking into consideration the environment, funding and mission we propose for 

your consideration a reduction in the proposed quarterly frequency to annual and increase in the 

minimum detectable leak rate from <1.5 gph to <3 gph. We believe most of the testing we have 

performed would be able to meet this requirement. We recommend this be the only option. To add 

another test at a lower sensitivity to any section where the MDLR is >3gph is not reasonable. In these 

cases we would be forced either use the more costly test method with a lower sensitivity or perform 

infrastructure changes.

We continue to evaluate the leak rate versus volume table you provide, but were unable to complete 

before submission of this document.

COMMENTS ON DRAFT DELIBERATIVE DOCUMENT – FIELD CONSTRUCTED USTS

We recommend options be added to accommodate monthly monitoring via ATG capable of achieving 

the following leak rate ranges, coupled with the related precision test frequency and leak rate:

 0.3 gph – 1 gph ATG MDLR coupled with a precision test every three years to 0.1 gph;

 1.0 gph – 2.0 gph ATG MDLR coupled with a precision test every other year to 0.1 gph

We concur with your proposed option to conduct annual precision test to 0.5 gph MDLR for USTs 

>50,000 gallons. However, there are a couple military locations unable to meet any of the options 

above. We need to discuss how to reasonably cover these facilities.

Regarding piping associated with these USTs, it is important to define the Field Constructed UST to 

include reasonable lengths of piping going from the UST up to the first isolation point as part of the UST. 

Also, underground pressurized piping originating from ASTs, piers, or defined as interstate/intrastate 

transfer piping should be excluded.
COMMENTS ON DRAFT DELIBERATIVE DOCUMENT – Scenarios 1-5

For scenarios 2, 3 and 5, it is important to state the definition of AST system to include AST and piping 

up to the UST (as long as the piping is less than 10% volume). We recall you stating that the leak 

detection applicability for the piping from the AST to the field constructed or traditional UST was “still 

under discussion”. NOTE: any piping that is >10% of volume of the AST(s) should be required to meet 

the release detection requirements as recommended above.

QUESTIONS/CLARIFICATIONS

Below, I would like to provide answers to other questions resulting from the meeting, as well as points 

of clarification.

Definitions for Airport Hydrant and Field Constructed USTs (and associated piping)

Due to the complexity and lack of similarity of our systems, it is difficult to provide a comprehensive 

definition. It may be best to simplify by illustrations similar to those provided in scenarios 1-5.

Separately, we recommend EPA provide clarification on how to reconcile potential dual regulation of 

field constructed USTs that are functioning as break out tanks.

Table of typical field constructed UST size, duration of test and leak rates

After review of select installations with field constructed USTs, we believe that most of the DoD owned 

USTs would be able to be compliant with the above options for leak detection. Typically, DoD field 

constructed UST s capacity range from 50,000 gallons to 2.2 million gallons. One installation has USTs 

with capacities that exceed 12 million gallons. Below is summary data for examples of select field 

constructed USTs and tests that have been performed. (Please note that although the MDLR 

represented below is achievable, it is very rare that we would be able to remove tanks from mission 

service for the length of time required, particularly for the 135’ and 122’ diameter tanks.)

Capacity Diameter Test Time MDLR

2.2M Gallons 135’ 288 Hours 0.1 gph

2.1M Gallons 122’ 192 Hours 0.1 gph

1.2M Gallons 99.5’ 96 Hours 0.1 gph

579,000 88’ 72 hours 0.1 gph

Diameter, length, volume and number of sections of hydrant piping
We estimate that piping diameter ranges from 4” to 20”. Piping lengths range from <50’ to >30,000 

feet. Volume ranges from <3,000 gallons to > 300,000 gallons. Number of test sections per facility 

range from 1 to >13.

Examples of fuel system layouts

Unfortunately, due to security reasons, we are unable to provide as is detailed drawings of our current 

systems. We are working on generic typical system layouts, but will be unable to meet your deadline. 

We will provide these as soon as possible.

Double-walled construction requirements for all new UST and pressurized piping facilities

During the meeting you referenced the above and the recent Energy Act. Can you provide clarification 

to this requirement and its applicability to Field Constructed USTs and Airport Hydrant Systems? As 

stated during our last meeting, double walled piping brings significant engineering challenges with 

providing adequate cathodic protection and release detection. As a result, the DoD standard design for 

underground piping is single-wall with cathodic protection and a maintenance schedule that includes an 

annual pressure test. In our experience properly maintained and protected single-walled piping is more 

protective of the environment than double walled piping due to the unreliable means of providing

cathodic protection and release detection.