1 

### DRAFT MEMORANDUM | 20 November 2008

TO 

### Cho-Yi Kwan and Tim Roberts, EPA

FROM 

### Cynthia Manson and Neal Etre, Industrial Economics, Inc.

SUBJECT 

### Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2-4, Work Assignment 1-25

EPA’s Office of Underground Storage Tanks (OUST) is currently exploring the
possibility of revising the existing regula tions associated with certain types of underground storage tank (UST) systems and equipment. Specifically, the Agency is considering amending the requirements to address four issues: (1)
technical/administrative fixes, (2) deferred UST systems, (3) existing regulatory gaps, and (4) potential deregulatory options.

Currently, the Agency is interested in de veloping a scoping analysis of the potential impacts of refining the existing regulations to do the following:

• Eliminate deferrals of release detecti on requirements for emergency generator
tanks under 40 CFR 280 SubPart D (40 CFR 280.40 ff );

• Eliminate deferrals of technical sta ndards and other requirements for field constructed tanks and airport hydr ant refueling systems under 40 CFR 280
Subparts B, C, D, and E, and G (40 CFR 280.2 ff) ;

• Require periodic tightness testing for spill buckets and sumps;

• Require leak detection and recordkeeping for spill buckets and sumps;

• Remove certain long-term recordkeeping requirements related to system repairs and testing; and

• Eliminate corrosion protection requirements for safe suction steel piping.

This memorandum provides an initial scoping-le vel analysis of the universe of facilities

and total annualized costs that would be asso ciated with these changes. The memo is organized to include:

• An overview of the baseline (existing) st ate regulations related to the targeted requirements, and an estimate of the nu mber and type of facilities and tanks likely to be affected by each requirement;

• A brief characterization of the facilities, locations, and industries likely to be affected by changes to the regulation;

• A summary table of estimated costs asso ciated with each of the changes under
examination; INTRODUCTION AND

BACKGROUND2 

### • A brief discussion of the general conclusi ons and next steps for refining this screening analysis; and

• Three detailed appendices documenting the methodologies, assumptions, and analyses used to examine the regulator y revisions under consideration.

o Appendix A describes the summary of baseline state regulations, and

also includes the evaluation of univ erse of facilities and costs associated

with removal of deferrals for emergency generator tanks, fieldconstructed tanks and airport hydrant refueling systems.

o Appendix B describes the evaluation of the universe and costs associated with the implementation of tight ness testing and vapor monitoring requirements for spill buckets and sumps.

o Appendix C describes the evaluation of cost savings associated with removing specific long-term recordkeeping requirements for repairs and testing, and the elimination of corrosion protection requirements for safe
suction steel piping.

Note that the analyses presented in this me morandum and appendices are all limited to initial, screening-level efforts to assess general facility universes and costs. They are
designed to help direct EPA’s efforts as th e Agency refines its priorities. To address uncertainties, we present ranges of results wh ere possible, and typically use conservative (i.e., high-cost) assumptions.

The purpose of this memorandum is to develop general conclusions about the total cost of regulatory revisions and the comparative costs of different potential actions. A key part

of this memorandum is the discussion of limita tions and recommendations for next steps.

The IEc team reviewed state regulatory inform ation to determine the states that currently (i.e., in the baseline) have regulations co nsistent with the revisions that EPA is
considering. The preliminary cost analyses assume that tanks in states with existing regulations incur no additional costs to co me into compliance with revisions to UST regulations. Exhibit 1 summarizes the status of current state regulations associated with

each of the revisions under consideration. Appendix A provides more detail on the methodology used to develop these estimates , and also provides a summary of the number of tanks of each type located in each state.

As Exhibit 1 indicates, fewer than half of all states and territories already have baseline regulations consistent with the revisions that EPA is considering. However, some of the

states that have removed deferrals from emer gency generator tanks and require tightness
testing of sumps are large states (e.g., California) with large populations of tanks.

Note that these results represent screening leve l analysis of state underground storage tank requirements. A more detailed examin ation of specific state requirements may
revise these initial findings if it is determined that state requirements are not consistent with EPA revisions or if additional state requi rements (e.g., fire control requirements) are identified that might effectively regulate the targeted tanks. SUMMARY OF

RELEVANT STATE

REGULATIONS3 EXHIBIT 1: SUMMARY OF STATE AND TERRITORIAL REGULATIONS RELATED TO DEFERRED

TANKS AND SPILL BUCKETS/SUMPS

State Emergency

Generator

UST

Release

Detection

Required

(Y/N) Airport

Hydrants

Deferred

from 40

CFR 280

Subparts

(Y/N) FieldConstructed

Tanks

Deferred

from

Subpart’s

(Y/N) Spill

Buckets/Sumps

Tightness

Testing

Required (Y/N)

B C D E G B C D E G

Alabama Y Partial Y N Y N Y Partial Y N Y N Y Y

Alaska Y Partial N Y N N Y Partial N Y N N Y N

American

Samoa N Y Y Y Y Y Y Y Y Y Y Y Y N

Arizona Y Y Y Y Y Y Y Y Y Y Y Y Y N

Arkansas N Y Y Y Y Y Y Y Y Y Y Y Y N

California Y N N N N N N N N N N N N Y

Colorado N Y Y Y Y Y Y Y Y Y Y Y Y N

Connecticut N Y Y Y Y Y Y Y Y Y Y Y Y N

Delaware Y Partial Y Y Y N Y Partial Y Y Y N Y Y

District of

Columbia Y Partial YYYNY Partial Y Y Y N Y N

Florida N N N N N N N N N N N N N Y*

Georgia N Y Y Y Y Y Y Y Y Y Y Y Y N

Guam Y N N N N N N N N N N N N N

Hawaii N Partial Y Y Y N Y Partial Y Y Y N Y N

Idaho Y N N N N N N N N N N N N N

Illinois Y Partial Y Y Y N Y Partial Y Y N N Y N

Indiana N Y Y Y Y Y Y Y Y Y Y Y Y N

Iowa N Y Y Y Y Y Y Y Y Y Y Y Y N

Kansas N Y Y Y Y Y Y Y Y Y Y Y Y N

Kentucky N Y Y Y Y Y Y Y Y Y Y Y Y N

Louisiana N Y Y Y Y Y Y Y Y Y Y Y Y N

Maine Y N N N N N N N N N N N N N

Maryland N N N N N N N N N N N N N Y

Massachusetts N N N N N N N N N N N N N Y

Michigan N Y Y Y Y Y Y Y Y Y Y Y Y N

Minnesota N Y Y Y Y Y Y N N N N N N N

Mississippi N Y Y Y Y Y Y Y Y Y Y Y Y N

Missouri N Y Y Y Y Y Y Y Y Y Y Y Y N

Montana Y Partial Y Y Y N N Partial Y Y Y N N N4 State Emergency

Generator

UST

Release

Detection

Required

(Y/N) Airport

Hydrants

Deferred

from 40

CFR 280

Subparts

(Y/N) FieldConstructed

Tanks

Deferred

from

Subpart’s

(Y/N) Spill

Buckets/Sumps

Tightness

Testing
Required (Y/N)

B C D E G B C D E G

Nebraska N Y Y Y Y Y Y Y Y Y Y Y Y N

Nevada N Y Y Y Y Y Y Y Y Y Y Y Y N

New
Hampshire Y N NNNNN N N N N N N Y*

New Jersey N N N N N N N N N N N N N N

New Mexico Y Y Y Y Y Y Y Y Y Y Y Y Y N

New York Y N N N N N N N N N N N N N

North

Carolina N Y YYYYY Y Y Y Y Y Y N

North Dakota N Y Y Y Y Y Y Y Y Y Y Y Y N

Northern

Mariana

Islands N Y YYYYY

Y Y Y Y Y Y N

Ohio N Partial Y Y Y N Y Partial Y Y Y N Y Y

Oklahoma N Partial Y Y Y N Y N N N N N N Y*

Oregon N Y Y Y Y Y Y Y Y Y Y Y Y N

Pennsylvania N N N N N N N N N N N N N Y*

Puerto Rico Y Y Y Y Y Y Y N N N N N N N

Rhode Island Y N N N N N N N N N N N N N

South

Carolina N Y YYYYY Y Y Y Y Y Y N

South Dakota N N N N N N N N N N N N N N

Tennessee N Y Y Y Y Y Y Y Y Y Y Y Y N

Texas Y N N N N N N N N N N N N N

US Virgin

Islands N Y Y Y Y Y Y Y Y Y Y Y Y N

Utah N Y Y Y Y Y Y Y Y Y Y Y Y Y*

Vermont Y N N N N N N N N N N N N N

Virginia N Y Y Y Y Y Y Y Y Y Y Y Y N

Washington Y Partial N Y Y N N Partial N Y Y N N N

West Virginia N Y Y Y Y Y Y Y Y Y Y Y Y N

Wisconsin Y Partial Y Y N Y Y Partial Y Y N Y Y N

Wyoming Y Y Y Y Y Y Y Y Y Y Y Y Y N5 State Emergency

Generator

UST

Release

Detection

Required

(Y/N) Airport

Hydrants

Deferred

from 40

CFR 280

Subparts

(Y/N) FieldConstructed

Tanks

Deferred

from

Subpart’s

(Y/N) Spill

Buckets/Sumps

Tightness

Testing
Required (Y/N)

B C D E G B C D E G

Total Yes 21 30 28 11

Total No 35 15 18 45

Total Partial NA 11 10 NA

* While these states have some baseline tightness testing requireme nts, it is not clear that they require tightness testing of sumps and spill
buckets after installation; therefore, they are not includ ed as “baseline requirements” in the analysis of costs.



### EPA’s potential regulatory revisions would affect four different populations of tanks:

• Tanks storing fuel to provide emergency generator support, with the exception of
emergency tanks at nuclear power plants;

• Tanks (both storage tanks and hydrants) that are part of stationary airport hydrant refueling systems;

• Field-constructed tanks; and

• Tanks, sumps, and spill buckets within the universe of facilities currently regulated under existing regulations.

Exhibit 2 provides summary information about the populations of each of these tanks, including information about the characteristi cs of the “industries” and facilities that use these tanks. Our preliminary investigation h as clearly identified only a small number of
sectors with significant numbers of specific typ es of tanks. At this time, field constructed tanks appear to be in the process of being phased out, and the small remaining population is used principally by the Department of Defense.

Similarly, airport hydrant refueling system s are relatively uncommon except for a small population at Department of Defense fac ilities and an even smaller population at commercial airports. Note that all of the se facilities appear to use aboveground storage
tanks as the principal storage unit for the hydrants, and may therefore not be subject to UST regulations. However, because the hydrants themselves are underground and could in some case, contain more than 10 percent of total system volume, we include all
hydrant systems in this screening assessment.

Exhibit 2 indicates that both commercial air port hydrant refueling systems and gasoline stations are in industry sectors that are dominated by small entities, with narrow profit
margins of less than five percent and av erage revenues less than $3 million. This
suggests that high capital or operations and maintenance (O&M) costs associated with revisions to the current regulations could have a significant impact on small businesses in TANK UNIVERSE AND

INDUSTRY

CHARACTERIZATION6 

### these sectors. Alternatively, reductions in the burden associated with current requirements may be valuable to facilities in these sectors. Note, however, that the North
American Industrial Classification System (NAICS) sector 48811 (Airport Operations) includes a range of airport operations from la rge commercial airports to general aviation facilities, and studies suggest that hydrant refu eling systems are concentrated at larger

facilities in this sector. 1 

### If that is the case, then Exhi bit 2 likely overstates the potential that small entities would be affected by regulation of hydrant systems.

Moreover, most airport hydrant refueling syst ems and virtually all field-constructed tanks
appear to be restricted to Department of Defense facilities; changes in the management of these tanks will have no impact on small businesses.

The regulations affecting sumps and spill buc kets, similar to most underground storage
tank regulations, address the entire universe of underground storage tanks. This universe is dominated by tanks operated by fuel servi ce stations. While underground storage tanks are used in a broad range of industrial sectors (a previous analysis for EPA relying on
state databases and industry associations has identified underground storage tanks in use in virtually every sector of the economy, including agriculture, commercial,
communications and utilities, construction, government, institutions, manufacturing,
mining, services, and transportation) the analyses concludes that over 80 percent of tanks

are associated with retail motor fuel sales. 2



### Therefore, as a simple screening approach, we examine spill bucket and sump impacts
assuming that all facilities with USTs are retail gasoline outlets, and have 2.65 tanks per facility. This assumption likely overstates small business impacts and facility-level implementation costs, and may understate to tal costs associated with paperwork (e.g.,
reading the regulations, recordkeeping requirements). However, given the uncertainty
about total number of facilities, we determined that an initial, simple approach is more easily modified as EPA refines its analysis.

The one specific population of tanks for which it has been difficult to make an industry characterization is emergency generator tanks. It is likely that these tanks are associated with a range of facility types and sizes, particularly manufacturing, research, power, and
medical facilities, but also hotels, recreation and sports facilities, and retail or wholesale sales and storage locations. A more detailed examination of these facilities is anticipated as a next step in assessing potential small busin ess impacts and costs; this revision could
in turn be used to update spill bucket and sump assumptions.

In addition, this analysis represents a sc reening level overview of general industry characteristics, but does not attempt to identif y or characterize specific facilities likely to
be affected by a change in regulation.

1 See, for example, Michael Kluttz, PE, “Aircraft Hydrant Fuel System Design Issues,” presen ted at The International Forum

on Emergency and Risk Management, Singap ore Aviation Academy, 10 – 12 January 2005

2 See Draft Industry and Facility Profiles, memorandum produced by E2 for EPA O ffice of Underground Storage Tanks,

December 18, 2006. E2 estimates that over 84 percent of roug hly 625,000 tanks are associated with retail fuel outlets.

While this estimate does not include tanks related to construct ion, mining, or tanks owned by the government, it is unlikely

that the dominance of retail gasoline outlets would be af fected by adjustments to i nclude these populations.7 EXHIBIT 2 TANK UNIVERSES AND INDUSTRY CHARACTERIZATION

TANK TYPE ESTIMATED

NUMBER OF

TANKS AND

FACILITIES IN

UNIVERSE a KEY SECTOR AND

NAICS CODE PERCENTAGE OF

“SMALL ENTITIES” b AVERAGE

REVENUES OF

SMALLER

FACILITIES IN

SECTOR c AVERAGE PROFIT

MARGIN OF SMALLER

FACILITIES IN SECTOR d

Emergency

Generator Tanks 199,526 tanks Varies; more

research needed TBD TBD TBD

Airport Hydrant Refueling Systems 201 hydrants National Security

928110 Not applicable N/A N/A

40 hydrants Airport Operations

48811/488119 e 89% of estab. In sector small (<$7 million revenue)

Note : hydrant systems likely concentrated at large facilities $1.8 million 4.5 percent (avg for all

facilities in sector
488119 w/ annual sales <$10 million)

Field Constructed

Tanks 239 tanks National Security

928110 Not applicable N/A N/A

Tanks with Sumps and Spill Buckets 629,866 tanks

237,865

facilities Gasoline Stations
w/Convenience

Stores f

447110 (80% of facilities) 47% small or singleunit estab. (sales less than $25 million) $2.3 million <1 percent

Other Gasoline

Stations

447190 (20% of facilities) 89% small or singleunit estab. (sales less than $8 million) $1.8 million 1.7 percent

Notes and Sources:

a. The estimate of tanks with sumps and spill buckets make a high-end assumption that all tanks are associated with gasoline stations and stations (f acilities) each have 2.65 tanks. This estimate does not attempt to estimate facilities that may have more tanks or may have tanks for othe r reasons (e.g., emergency generator tanks).

b. Small facility percentages are base d on revenue definitions from the Small Business Administration (SBA) ( http://www.naics.com/sba_sizestandards.htm ), combined with information on the distribution of establishments of different sizes within specific NAICS codes from the U.S. 20 02 Census of Manufactures. For gasoline stations, single establishment revenues are almost always under small business size limits; ther efore all single-unit facilities are

considered small businesses. Information on distribution of revenues per facility is at http://www.factfinder.census.gov/servlet/IBQTable?_ bm=y&-NAICS2002=447110&-ds_name=EC0244SSSZ4&-_lang=en

and http://www.factfinder.census.gov/s ervlet/IBQTable?_bm=y&-NAICS2002=447190&-ds_name=EC0244SSSZ1&-_lang=en

for stations with and without convenienc e stores, respectively. Information on single and multi-unit firms is at: http://factfinder.census.gov/s ervlet/IBQTable?_bm=y&-ds_na me=EC0244SSSZ3&-NAICS2002=447190 and http://factfinder.census.gov/s ervlet/IBQTable?_bm=y&-ds_na me=EC0244SSSZ3&-NAICS2002=447110 for gasoline stations without and with convenience stores, respectively.

c. Revenues represent weighted average revenues reported by the U.S. 2002 Census of Manufacturers for facilities with

revenues less than SBA size standards. See Ce nsus information outlined in note b above.

d. Average profit margins based on Risk Ma nagement Associations’ 2006-2007 Annual St atement Studies. Profits after taxes identified as average for facilities in NAIC S codes with revenues less than SBA standards

e. Sector 48811 includes a range of operations (e.g., fuel supply, air traffic control) at airports of different sizes; the airports that employ hydrant refueling sy stems are likely larger than average facili ties in this sector. Therefore, this information may overstate the percen tage of hydrant systems that are operated by small entities.

f. The Census definition of convenience stor ies is not specific; in contrast, the Na tional Association of Convenience Stores specifies off-street parking, a specific range and number of products for sale (totaling over 500 products), square footage, and extended hours of operation as part of the definition of “c onvenience store.” To the extent that the

Census facilities differ from NA CS facilities, it will be necessary to reconc ile these definitions to develop an accurate

estimate of the number of USTs asso ciated with convenience stores.8 SMALL BUSINESS SCREENING METHOD 

### To assess the potential small business impacts, the IEc team used a simple screening
approach that cross-references Small Business Administration (SBA) data on small

business size classes with U.S. Census data identifying establishments by size.

For airport hydrant refueling systems, IEc identified Airport Operations (NAICS code
48811 and 488119) as the relevant industry; the SBA revenue standard for this industry is $6.5 million per year in sales. The 2002 Economic Census data for NAICS code 488119 identified that 89 percent of establishments in the sector (which includes a range of operations) report annual sales of less than $7 million. IEc then calculated average
revenues for these facilities by using a weight ed average of the number of facilities in each U.S. Census revenue category and the mid-point value of the revenue category
range. Finally, IEc examined average profit profiles from companies in the sector using Risk Management Associates’ Annual Statement Studies.

To the extent that the airports with hydr ant refueling operations are representative of
establishments in NAICS code 488119, it is possible that several of these refueling systems are associated with small businesses. However, it appears likely that hydrants are used only at larger facilities; in this case small entity impacts would be limited.
Furthermore, only 40 facilities in a sector of over 1,100 establishments are at issue, suggesting that the total number of affected facilities is unlikely to meet the threshold for

a “substantial number” of small entities. 3



### To identify a “worst case” screen of the sma ll business impacts associated with regulating spill buckets and sumps, the analysis assumes th at all facilities are gasoline stations. This screen does not consider the range of indust ries associated with emergency generator
tanks, or industries that employ fleet fu eling facilities. While a more detailed examination of these sectors will provide a better estimate of the total number of small entities affected, it is likely that gasoline stations have a higher (i.e., worst case)
proportion of small entities than most other sectors with USTs.

For retail gasoline stations, IEc identified two relevant NAICS codes: 447110 (Gasoline
Stations w/Convenience Stores) and 447190 (O ther Gasoline Stations) with $25 million and $8 million SBA size standards for annual sales, respectively. IEc employed the
same methodology with the same data sour ces, with one additional step: we also examined Census data on the number of singl e-unit and multi-unit firms in the industry.
In the case of Gasoline Stations w/Convenience Stores, while over 99 percent of all establishments report sales of under $25 million, roughly half of these establishments are
in multi-establishment firms; the initial scr eening assessment assumes that only singleunit establishments (47 percent of the total) in this sector are small businesses. Similarly, for Other Gasoline Stations, almost 95 percent of establishments report sales under the SBA size standard of $8.0 million, and only 10 percent of establishments are multi-unit.
Therefore, the initial screening assessment conc ludes that at least 89 percent of these establishments are likely to be small businesses.

3 Because only 40 commercial facilities have hydrant system s, and because some of these are likely to be aboveground

systems, it is unlikely that a “substantial number” of small entities would be affected in any scenario.9 NOTE ON SPILLS FROM KEY TANK POPULATIONS 

### As one part of this screening analysis, the IE c team attempted to identify the number of
leaks associated specifically with deferred ta nk systems, and determined that no national level data sources provide sufficient informati on to isolate spills associated with specific tanks. The main national reporting system for oil-related releases is the Emergency
Response Notification System (ERNS). ERNS is a database of oil and chemical spill incidents reported to the U.S. Coast Guard through its National Response Center, and includes spills from any facility that meet cer tain “reportable quantity” definitions.
However, ERNS data does not consistently pr ovide detailed information about the type of facility or source (i.e., tank) associated with the spill.

State data sets may in some cases include information about leaks from tank systems
deferred under Federal regulations, particularly in states that do not defer these systems. One potential approach to calculating the num ber of spills from deferred systems would

be to collect and review data from states that require reporting from the relevant systems.
If state data include sufficient descriptive tank information to identify specific tank types, then a systematic evaluation of the number of leaks from key tank populations may be possible. However, it is important to not e two key limitations to this approach:

• It is not clear at this time whether any st ates routinely track information that would

allow identification of the specific tank populations in question (i.e., airport
hydrant refueling system tanks, emergenc y generator tanks, a nd field-constructed
tanks); and

• It is not clear that states with reporting requirements for deferred systems are

representative of national practice. If, for example, target states have more
stringent requirements in other aspects of tank operations, then leaks may have
different frequencies than leaks in other states.

Using the information gathered about tank and facility popula tions and the data available on baseline state regulations, we have developed preliminary cost estimates for each of
the regulatory revisions under examination. While each regulatory revision requires a slightly different methodology, all methodologies involve the same basic approach:

• Identification of the universe of tanks and facilities likely subject to regulatory
changes;

• Identification of the number of tanks and facilities regulated in the baseline by state or other Federal regulations;

• Estimation of the unit costs associated with capital, O&M, and recordkeeping activities that will change under the revisions under consideration; and

• Adjustment as necessary to identify one-tim e, annual, total, and total annualized
costs associated with the regulatory revisions.

Exhibit 3 shows the preliminary cost estim ates for each of the proposed regulatory

revisions. Note that these initial estimat es for emergency generator USTs and for
regulations affecting spill buckets and sumps make the simplifying assumption that the each facility has an average number of 2.65 ta nks. Particularly for emergency generator SUMMARY OF

COST ESTIMATES

FOR REGULATORY

REVISIONS10 

### USTs, this assumption is likely to requi re revision as more refined analyses are developed. Until a better estimate of specific tank populations (e.g., emergency generator tanks) is available, however, a simple, consistent assumption appears reasonable.

COSTS ASSOCIATED WITH PROPOSED REGULATORY REVISIONS

PROPOSED REVISION NUMBER OF TANKS

OR FACILITIES

AFFECTED ONE-TIME COSTS

PER FACILITY TOTAL ONETIME COSTS ANNUAL COSTS PER

FACILITY TOTAL ANNUAL

COST IMPACT

Removal of Subpart D

Deferral for Emergency Generator

USTs 129,364 tanks;
48,817 facilities $164.50 For reading regulations $8.0 million ~$404 $19.7 million

Removal of Subpart B,C,D,E, and G Deferrals for Airport Hydrant Refueling Systems 241 tanks; 91

facilities (38 – 56% of hydrants regulated

in baseline for different Subparts) Retrofit costs

for older existing

facilities –
$26,500 - $274,000 per facility Unknown –

could be

several

million

dollars if

feasible ~$342

Doesn’t include

O&M costs for upgraded leak detection systems $0.08 million

Removal of Subpart B,C,D,E, and G

Deferrals for FieldConstructed USTs 239 tanks;

90 facilities (55 – 88% of tanks regulated in

baseline for different Subparts) $493.5 For reading regulations $1,645 ~$953 $0.06 million

Tightness Testing for Spill Buckets (1 & 3- yr testing)

629,866 tanks;
237,685 facilities

(~14% of tanks

regulated in

baseline) $64.75 For reading regulations $15.4

million $21 - $68 million $121 - $317

million
Includes $4 -
$6 million in recordkeeping

Excludes repair costs Tightness Testing for Sumps (1 and 3 year) $28 - $87 million

Tightness Testing for Dispenser Pans (1 and 3 year testing) $68 - $210 million

Leak Detection for Spill Buckets (6 or 12 mos recordkeeping) $129.75 For reading regulations $30.8

million $102 – $177 million

$425 – 728

million
Includes $16 -
$20 million in recordkeeping Leak Detection for Sumps (6 or 12 mos) $102 – $177 million

Leak Detection for Dispenser Pans (6 or 12 mos) $205 - $354 million

Reduction in recordkeeping for repairs 18,875 facilities

per year Not calculated Not

Calculated $3.15 - $4.42 savings - Reflects

range of time

frames Savings of
$0.06 - $0.08

million

Reduction in leakdetection recordkeeping 237,533 facilities Not calculated Not

Calculated $18.81 savings Savings of
$4.47 million

Elimination of corrosion protection requirements for safe suction steel piping Very small number

of facilities and tanks; declining Not calculated Not

Calculated Not Calculated Not Calculated EXHIBIT 311 

### As Exhibit 3 illustrates, the potential costs asso ciated with the regulatory revisions range
considerably, including costs that range from less than $100,000 to over $700 million, and cost savings that range from less than $100,000 to over $4 million. The combination
of a large population of tanks and high cost s associated with additional equipment and
testing result in very high costs associated with regulating spill buckets and sumps.

Additional scenarios that consider the costs of repairs to sumps and spill buckets that fail tightness testing and also consider continuous au tomated leak detections calculate costs in
excess of $1 billion; these scenarios are c onsidered in detail in Appendix A.

In contrast, the small universe of airport hy drant refueling systems and field-constructed tanks, combined with existing state regula tions and requirements under 40 CFR 112 (the
SPCC regulations) result in very modest cost impacts associated with removing deferrals from these tanks. Cost savings estimates are al so driven by the number of facilities; costs per facility are modest in all cases.

Detailed information about the methodologies and data used to develop these estimates is presented in Appendices A, B, and C. However, a number of key assumptions and limitations for each regulatory revision are noteworthy:

• Emergency Generator USTs: The costs of removing the Subpart D deferral from emergency generator USTs are driven largely by the number of tanks and facilities. For this screening analysis, a high-end estimate of the number of
emergency generator USTs was developed by assuming that all non-gasoline station USTs are emergency generators. A more refined estimate of this set of

tanks could reduce the total cost estimate.

• Airport Hydrants: Airport hydrant system costs reflect two significant assumptions. First, it is assumed that only the hydrants are targeted by the regulation because storage tanks associated with these systems are typically
above-ground storage tanks (ASTs). Second, it is assumed that these systems, in part, are subject to standards under the SPCC regulations that are relatively

consistent with the revisions under consid eration by OUST, and will therefore not
require significant capital upgrades. 4 

### However, retrofitting older systems with leak detection and tightness testing capabilities under Subpart D may be expensive or infeasible – more informa tion is needed to determine how many
facilities would require this and what unit costs would apply.

• Field-Constructed Tanks: Field constructed tank costs reflect an assumption that existing tanks are generally complia nt with SPCC regulations and current
industry standards and will not require significant capital upgrades. This assumption may be less valid for piping a nd spill control systems associated with

4 While SPCC regulations do not specify pa rticular leak detection protocols, the re gulations require that plans conform with

industry standards, and these can often be consistent with UST requirements. For ex ample, industry standards relevant to

leak detection identify commonly used inventory management systems such as au tomated tank gauging (ATG) systems and

other types of inventory reconciliation, wh ich provide continuous monito ring of the entire system and can alert operators to

leaks.12 

### the tanks; if it is determined that these systems require upgrades beyond those required by SPCC, then cost estimat es for this revision could increase.

• Tightness Testing for Spill Buckets and Sumps: The main uncertainty associated with the costs of this regul atory revision is the treatment of the additional repair costs that will also result due to improved information from
tightness testing. These repairs are not currently specified under existing Federal and state regulations, but could reasona bly be considered baseline compliance costs. The current analysis summarized in Exhibit 3 does not include these costs,
but Appendix A provides an estimate of their potential magnitude; they could represent an additional $64 - $231 million per year.

• Leak Detection for Spill Buckets and Sumps: The significant cost range for
this regulatory revision results from uncer tainty about what technology will be
used. Fixed, automated leak detecti on methods are both very expensive and potentially ineffective. Alternative meth ods that address only facilities that have
failed tightness testing have lower costs and have been estimated in general, but it is not clear whether these alternatives are consistent with EPA priorities.

• Cost Savings for Reductions in Recordkeeping: The estimates of reductions in
recordkeeping costs are initial, high-end estimates of cost savings. They do not

correct for the cost associated with readi ng regulations, or the potential that some states may not be able or willing to im plement the same regulatory revisions.
This issue will affect all cost-saving or de-regulatory options, and may be important to clarify.

• Safe Suction Steel Piping: Preliminary research on the use of safe suction steel
piping suggests that it is a rare and diminishing technology, and that cost savings associated with removing corrosion protec tion requirements would have modest impacts, if any.

These analyses provide a reasonable screening level overview of the potential costs and cost savings associated with the various regul atory revisions identified by EPA. Based on
the analysis, several initial conclusions can be drawn, as follows:

• Regulatory changes targeted at field- constructed tanks and airport systems

will have limited impact: The populations of these tanks and systems are small,
and are dominated by Department of Defense facilities. It does not appear that a
significant number of new systems is being installed. Moreover, a number of
states and SPCC regulations are likely to assure that tanks, and to some extent
piping and spill control, are consistent w ith UST regulations. As a result, both the
costs and the impacts associated with removing deferrals on these types of tanks
are likely to be modest.

• Tightness-testing and vapor monitoring of sumps is likely to incur significant

costs: The number of facilities affected by tightness-testing and vapor monitoring
of sumps ensures that the costs of these regulatory revisions will be significant, and will likely be in excess of $100 million. A number of states address tightness GENERAL

CONCLUSIONS AND

NEXT STEPS13 

### testing, but not all of these appear to address sumps and spill buckets, though
further investigation could identify addi tional regulations (e.g., fire prevention
regulations) that address vapor monitoring. These actions may also have impacts
on small businesses, given the dominance of small entities in the gasoline station

sector.

• Cost savings efforts could be significant, but will depend on state

implementation procedures: Cost savings associated with streamlining of
recordkeeping and other activities could be significant if a large number of
facilities are affected by the regulation. As noted, an 19 dollar savings per facility results in annual cost savings of over $4 million nationally. However, this initial
exercise did not address the limitations on de-regulation that result from state
restrictions or procedures that could prevent the implementation of cost-saving

actions.

These conclusions, and some of the limitati ons of the screening analysis, suggest the following next steps as EPA continues to assess regulatory revisions:

• Clarify certain “standard” issues that will affect all regulatory changes.
These include the limited ability of states to implement de-regulatory changes as
noted above, and the need to clarif y and harmonize the interpretation of paperwork requirements to ensure consis tency and accurate estimates of costs
associated with actions such as “reading regulations” that can affect multiple

revisions.

• Collect additional information clarifying tank and facility populations. This
screening assessment uses several simplifyi ng assumptions that should be refined to support a more detailed cost assessment . Specifically, the number of tanks at facilities (assumed to be 2.65 tanks per facilities for this screening assessment) is
not likely to be accurate when addressing em ergency generator, field constructed, and airport hydrant system tanks, and should be updated if EPA examines these populations more closely. Similarly, the industry sectors of importance may vary
depending on the populations of tanks, and should be re-examined as specific popultions are examined more closely. The initial assumption that “all tanks are at gas stations” provides a conservative (i.e., high-end) estimate of the potential
number of small businesses affected, but does not provide resolution about specific industry impacts associat ed with different tank types.

• Address largest sources of uncertainty in cost estimates. Of the options
considered in this analysis, the variables most likely to drive the largest costs are the selection of options for implementing vapor monitoring of sumps and spill
buckets, and the extent to which new regulations would require additional
maintenance and repair. Another issu e of importance may be the remaining uncertainty regarding the extent to which states already address these activities through various regulatory frameworks. Gi ven the large costs at issue, closer
examination of this issue may be useful.14 

### • Consider a broader analysis of de-regulatory options. A review of the ICR materials indicates that OUST regulations in total impose a significant paperwork
burden on regulated facilities. It may be possible to identify further opportunities to streamline regulations without aff ecting environmental quality, if EPA determines that a further review of options is worthwhile.

### Appendix A

### 1 300 North Lee Street, Suite 201 • Alexandria, VA 22314 • (703) 684-2060 (phone) • (703) 684-5343 (fax)



### MEMORANDUM July 2008

To: Cynthia Manson, IEc From: John Chang, Quinton Ford, Rick Cool, Nandina Jinnoharra, and Frank Marcinkowski, PCCI

Subject: Summary of the Preliminary Asse ssment of Baseline and Cost Impacts Associated with Deferred UST Systems

Overview of Memorandum

This memorandum summarizes PCCI’s initial, screening-level char acterization of the existing state underground storage tank (U ST) regulations, the population of each deferred UST for characterization, and the uni t and compliance cost estimates. PCCI did not contact any states to obtain inform ation or data. The memorandum presents:

• A summary of the current state UST regulations.

• A description of the assessment methodol ogy, including the iden tification of the main sources of data and information, assumptions, and limitations.

• A set of tables that present the charac terization results for each deferred UST population.

• A summary of the overall c onclusions about the cost es timates, including the key

uncertainties of the results and additional in formation needs to refine the results.

Subtask A: Summary of State Regulations

Description of Methodology

PCCI used two main sources to screen the state UST regulations:

• The U.S. EPA OUST UST program website pages containing information on the state UST programs and regulations.

• Where promulgated, each state’s UST regul ation. PCCI downloaded current state UST regulations from websites maintained by each state agency.

### 2 PCCI screened the applicability and exem ptions or deferrals in each available promulgated state UST regulation to determin e the status of the pertinent equipment under the state UST programs. PCCI did not review the technical standards in the state regulations but assumed that the require ments in the state regu lations are at least as stringent as those in 40 CFR 280.

Summary of Results

• Exhibit 1 identifies the states that follo w/adopted 40 CFR 280 and the states that have promulgated UST regulations.

• Exhibit 2 summarizes the deferral status of emergency generator USTs, airport hydrants, and field-constructed USTs for each state and territory. Exhibit 2 also

identifies those states and territories that require tightness testing of UST spill buckets and sumps.

• Attachment 1 to this memorandum identif ies the states and territories with approved UST regulatory programs and/or UST regulations and contains the URLs to access the UST regulations as of June 2008.

Subtask B: Characterization of Tank Universe for Selected Tank Types

Description of Methodology

• EPA’s semi-annual UST and LUST performa nce measures report for end of FY 2007 provided the number of active USTs for each state. 1



### • To estimate the potential number of emer gency generator USTs, field-constructed USTs, and hydrants in the U.S.-

o PCCI obtained the number of fuel service stations for each state from the Energy Information Administration’s st ate energy profiles published at the agency’s website. 2



### o PCCI estimated the total nu mber of fuel service station USTs in each state by multiplying the number of service stations by 2.65 USTs per facility. This the same assumption of 2.65 USTs per facility in EPA’s 24 October

2007 ICR 1360.08.

1 EPA OSWER, FY 2007 End-of-Year Activity Report, December 5, 2007, http://www.epa.gov/OUST/cat/ca_07_34.pdf

2 Energy Information Administration, State Energy Profiles, April 2008 Update, http://tonto.eia.doe.gov/state/

### 3 o The total service station USTs exceeded the total active USTs identified in the EPA FY 2007 End-of-Year Activity Report in several cases by using 2.65 USTs per service station. For these cases, PCCI reduced the assumption of USTs per facility to eith er 2 or 1 UST per service station to

estimate the total number of service st ation USTs so as not to exceed the total number of active USTs for the particular state.

o PCCI obtained the number of DoD ow ned or operated field-constructed USTs and their locations by state fr om the Defense Energy Support Center (DESC). 3 

### Conversation with representative s of commercial firms involved with the operations and maintenance of field-constructed USTs concerning estimates of non-DoD owned or operate d field-constructed USTs in the U.S. indicated that it is very likely that DoD is the only organization that still owns or operates field-constructed USTs. 4 

### Subsequently, PCCI assumed that DoD owns and operates most of, if not all, the fieldconstructed USTs in the U.S. This a pproach produced an estimate of 239

field-constructed USTs in the U.S.

o PCCI reviewed the FAA U.S. airport classifications to estimate the

number of commercial ai rport hydrants in the U.S. 5 

### According to the airport classifications, there are 40 class B airports in the U.S. Class B airports are the largest commercial ai rports that typi cally employ fixed hydrant fueling systems as part of the airport infrastructure. A 1993 ASTM paper by Jairus D. Flora et al., also reported that there are about 40 hydrant systems in the U.S. 6



### o PCCI assumes that aboveground stor age tanks supply the airport hydrant systems for this screening-level characterization. API/Energy Institute Recommended Practice 1540, Design, Construction, Operation and Maintenance of Aviation Fuelling Facilities, 4 th 

### Edition, interprets a hydrant system as a “system that allows for aviation products to be pumped direct from an airfield depot or satellite depot to a parking apron for delivery in bulk to aircraft.” Hydr ants are the pressurized fuel transfer equipment in airport fueling systems. In addition, storage tanks for fixed airport hydrant systems are usually aboveground vertical steel storage

tanks. 7 

### If an airport fueling system uses USTs, the USTs are not deferred

3 Laura Curtis, DESC, (703) 767-8312. DESC is responsible for supplying DoD with bulk aviation and ground fuels. DESC owns all the bulk petroleum produc ts from the point of purchase until its final point of issue to aircrafts, ship s, and ground equipment.

4 Communications between Quinton Ford, PCCI and Tim Garner, Garner Environmental Services, (301) 865-2111and Dennis O’berdove, Tank Integrity Services, (440) 237-9200, 11 June 2008

5 DOT/FAA Order JO 7400.9R, Subject: Airspace Design ations and Repo rting Points, 15 September 2007.

6 Flora, J. D , Jr , Glauz, W. D., and Hennon, G. J , "Leak Detection Methods for Airport Hydrant Systems," Leak Detection for Underground Storage Tanks, ASTM STP 1161, Philip B Durgin and Thomas M. Young, Eds., American Society for Tes ting and Materials, Philadelphia, 1993.

7 Michael Kluttz, PE, Aircraft Fuel Hydrant System Design Issues, The International Forum on Emergency and Risk Management, Singapore Aviation Academy, 10 – 12 January 2005

### 4 from any of the technica l standards in 40 CFR 280 or in approved state UST programs under 40 CFR 281.

o PCCI also obtained the number of DoD owned or operated airfield hydrants (201) and their locations by state from the Defense Energy Support Center (DESC). DESC is re sponsible for supplying bulk aviation fuel for these hydrants. However, the center is not responsible for supplying fuel to all DoD hydrants in the U.S.

o To estimate the DoD hydrants that DESC does not supply bulk aviation fuel to operate, PCCI compiled a list of DoD airfields, ai r stations, and air

bases in the U.S. 8 

### Initially, PCCI assumed that each identified installation operates at least one hydrant. This approach produced 279 DoD hydrants,

which PCCI assumed included the 2 01 hydrants identified by DESC.

PCCI believes that the actual number of DoD hydrants is likely much lower than 279, but it is at least 201 hydrants at present. For instance,

based on PCCI’s work with Air Nationa l Guard bases, not all Air National Guard bases operate hydrants; these base s often use refueler trucks to fuel

aircrafts. USCG air stations that are co-located on other DoD service component installations likely use the same service components’ hydrants

at these installations.

o For this screening, the estimate of the total airport hydrants in the U.S. is 201 DoD hydrants together with 40 commercial airport hydrants or 241 hydrants.

o PCCI estimated the number of nucle ar emergency generator USTs by reviewing the Energy Informa tion Administration’s published compendium of nuclear reacto r facilities for each state. 9 

### PCCI assumed 1 emergency generator UST per nuclear reactor facility, producing an estimate of 104 nuclear emergency generator USTs.

o Finally, to obtain an estimate of th e number of emergency generator and other USTs in each state, PCCI subt racted the number of fuel service station, field-constructed, and nuclear reactor facility emergency generator

USTs from the total active number of USTs for each state. As a screening estimate, PCCI assumed that all “other” (i.e., not fu el service station, field constructed, or nuclear facility emer gency generator) USTs in each state are essentially emergency generator USTs.

8 GlobalSecurity, as of June 2008, http://www.globalsecurity.org/military/facility/

9 Energy Information Administration, States with Commercial Nuclear Industries, as of 22 October 2007, http://www.eia.doe.gov/cneaf/nuclear/p age/at_a_glance/reactors/states.html

### 5 • Regarding the equipment size, facilit y, industry NAICS code, and annual number of leak incidents dealing with field-c onstructed and emergency generator USTsand hydrantso Review of the UST registration/perm it information and leak incident reports collected by each state will be required to identify the UST size, facility, industry NAICS code, and annual number of leak incidents for emergency generator USTs. This conclusion is based on PCCI’s screening of the UST information presently co llected and reported to the public by EPA, the information collected by each state as reported on their internet sites, and knowledge of the spill data and their metadata in the NRC spill database and EPA’s Facility Oil Spills Database.

o For this screening, PCCI assumed that the 239 field-constructed USTs in

the U.S. are DoD USTs. The NAICS industry code is 928110, National Security. 10 

### As 40 CFR 280 and various st ate UST regulations defer fieldconstructed USTs from notification re quirements, determining the size of the field-constructed USTs will require surveying operators and/or states that require notification for the inform ation (DoD). As shown in Exhibit 4 summarizing the field-constructed US T deferral status, over 75% of these USTs are subject to state notification requirements. Review of the leak incident reports collected by states will be required to identify the annual

number of leak incidents for the fi eld-constructed USTs, assuming that states require the reporting of leaks from these types of USTs. Exhibit 4 shows that the majority of the operato rs of field-constructed USTs (88%) are required to report releases to states.

o The NAICS industry code for DoD h ydrants is 928110, National Security, while the NAICS industry code for commercial airport hydrants is 488190, Other Support Activities for Air Transportation. As 40 CFR 280 and various state UST regulations defe r airport hydrants from notification requirements, determining the hydran t capacities and sizes will require surveying states and/or operators for the information (DoD and commercial airport authorities). As in the case of field-constructed USTs and emergency generator USTs, review of the leak incident reports collected by states will be required to identify the annual number of leak incidents for hydrants, assuming that st ates require the reporting of leaks from airport hydrants. Exhibit 4 shows that in state UST regulations about 50% of hydrants remain deferred from the standards that are otherwise

deferred under 40 CFR 280.

Summary of Results

• Exhibit 3 summarizes the estimate of the universe of field-constructed and emergency generator USTs and airpor t hydrants in the U.S. by state.

10 U.S. Census Bureau, Bridge Between NAICS and SIC, 1997 Economic Census, June 2000.

### 6 Subtask D: Unit Costs and Compliance Cost Estimates

Description of Methodology

• PCCI derived the screening cost esti mates for the field-constructed USTs, emergency generator USTs, and airpor t hydrants based on costs in the EPA OUST ICR Number 1360.08, 24 October 2007.

• Attachments 2 to 12 are the cost work sheets, which are based on the annual

estimated cost burden worksheets for the pertinent 40 CFR 280 subparts in

Exhibit 1 of the EPA 24 Oct ober 2007 ICR Number 1360.08. The cost worksheets show the assumptions unde rlying the estimate of the costs for removing the deferrals of the pertin ent 40 CFR 280 subparts for emergency generator USTs, Attachment 2; field-cons tructed USTs, Attachments 3 to 7; and airport hydrants, Attachments 8 to12.

• To estimate the costs of requiring annual spill bucket or sump tightness testing,

PCCI obtained estimates of the test cost s per spill bucket or sump from three firms that specialize in providing the tests. 11 

### Test costs range from $100 to $400 per spill bucket or sump.

Summary of Results

• Exhibit 4 identifies the numbers of field- constructed USTs, the states in which they are located, and the numb ers of tanks deferred for the subparts of interest in the respective states.

• Exhibit 5 identifies the number s of airport or airfield hydr ants, the states in which they are located, and the nu mbers of hydrants deferred for the subparts of interest in the respective states.

• Exhibit 6 estimates the cost of requiri ng annual spill bucket or sump tightness testing.

• Exhibit 7 is the estimate of the cost of removing the deferral of the release detection standards in Subpart D for emergency generator USTs.

o As emergency generator USTs are not subject to all of the technical standards of 40 CFR 280, includi ng those deferred from specified standards in state UST programs approved under 40 CFR 281, they are subject to the SPCC requirements in 40 CFR 112. 12 

### Under 40 CFR 112,

11 Ed Kubinski, Crompco, (800) 646-3161; Tim Garner, Garner Environmental Services, (301) 865-2111; Dennis O’berdove, Tank Integrity Services, (440) 237-9200.

12 40 CFR 112.1(d)(4)

### 7 completely buried tanks must be regula rly leak tested in accordance with good engineering practice. Note that under 40 CFR 112, bunkered tanks and partially buried tanks are consid ered aboveground storage containers subject to the requirement s of the SPCC regulation. 13



### o These USTs, as bulk storage contai ners under the SPCC regulation, have to be constructed, operated, and tested regularly to pr event and control spills in accordance with good engineering practice.

• Exhibit 8 shows the estimates of the cost of removing the deferra l of the standards in Subparts B, C, D, E, and G for field-constructed USTs.

o As field-constructed USTs are not subj ect to all of the technical standards of 40 CFR 280, including those deferred from specified standards in state UST programs approved under 40 CFR 281, these USTs are subject to the SPCC requirements in 40 CFR 112. Under 40 CFR 112, completely buried

field-constructed tanks have to ha ve corrosion protection and must be regularly leak tested in accordan ce with good engineering practice.

o These USTs, as bulk storage contai ners under the SPCC regulation, have to be constructed, operated, and tested regularly to pr event and control spills in accordance with good engineering practice.

• Exhibit 9 shows the estimates of the cost of removing the deferra l of the standards in Subparts B, C, D, E, and G for air port hydrants based on assumptions identified below and in the attached hydrant cost worksheets. However, based on below raised points concerning the wide range of potential release detection costs for hydrants, more information needs to be co llected and reviewed to obtain a more

effective cost characterization of the air port and airfield hydrant systems in the U.S., particularly with respect to hydrant leak detection and location technologies and equipment in use and th eir costs. For instance, 98 out of the 241, or 41%, airport/airfield hydrant syst ems in the U.S. are subject to the release detection

standards established in st ate UST regulations. Consequently, one way to obtain the needed information is by surveying th e states that do not defer hydrants from the requirements that are otherwise deferred under 40 CFR 280, in addition to surveying the hydrant operators.

o PCCI assumed that hydrants are de signed or retrof itted with cathodic protection and have rele ase detection, and operato rs perform integrity testing per industry standards. About 41% of the hydrants in U.S. are not deferred from release detection requ irements under state UST regulations.

As in the case of field-constructed USTs, airport hydrants are subject to the SPCC requirements of 40 CFR 112 as the hydrants are deferred from

certain technical standards in 40 CFR 280.

13 Definitions of “bunkered tank” and “completely buried tank” in 40 CFR 112.2.

### 8 o Hydrants are the pressurized compone nts of the aircraft fuel delivery system; they are not specifically US Ts. Storage tanks for fixed airport hydrant systems are usually abovegr ound vertical steel storage tanks. Regardless of the type of storage ta nk, however, if over 10 percent of the total volume of fuel stored in a hydran t system is stored underground (i.e., in the hydrants) then the systems represent deferred underground storage

systems.

o Newer hydrants are likely designed with leak detection and tightness testing capabilities for a va riety of reasons, for inst ance, to meet the spill prevention and control requirements of 40 CFR 112 and those established by certain states. For instance, it is li kely that airport hydrant operators do inventory reconciliation for business reasons; inventory reconciliation is done for the entire fuel system, including the hydrant system. Older hydrants may require retrofitting with leak detection technology that meets the leak detection and tightness test ing standard for pressurized piping.

o Retrofitting older hydrants with technology that m eets the leak detection and tightness testing standards for pressurized piping in 40 CFR 280 Subpart D may not be feasible or presen t a wide range of costs to install, operate, and maintain, depending on s ite conditions. For instance, it may

not be feasible or cost effective to retrofit an existing hydrant system with double-wall piping and in terstitial monitors.

 The U.S. Army Corps of Engineers reviewed eight main passive

leak detection and location tec hnologies for pipelines based on surveys of vendors to obtain maintenance, installation, and material costs for the hydrants surveyed on site visits to 1 commercial and 7 DoD hydrant operators. 14 

### This guide is in Attachment 13. Installation, equipment and construction material costs ranged from $26,250 to $274,000 depending on the technology and hydrant piping lengt hs. The guide reported annual maintenance costs that were available ranging $300 to $25,883, again depending on the technology. To tal cost per foot of piping ranged from $9.85 to $66.00.

 The leak rates from airport hydran ts, which are large pressurized fuel containing systems, depend on the hydrant capacity and pressure. Increasing system size re quires increasing leak detection

accuracy. 15

14 U.S. Army Corps of Engineers Public Works Technical Bulletin 420-49-36, 15 June 2001.

15 Flora, J. D , Jr , Glauz, W. D., and Hennon, G. J , "Leak Detection Methods for Airport Hydrant Systems.” (p.33).

## Exhibits

### Exhibit 1. State UST Program and Regulations Status

State Approved

State Program

(Y/N) a 

### State Regulations (Y/N) b 

### State adopted

40 CFR 280 (Y/N) c



### Alabama Y Y N

Alaska N Y N

American Samoa N N N

Arizona N Y N

Arkansas Y N Y

California N Y N

Colorado Y Y N

Connecticut Y Y N

Delaware Y Y N

District of Columbia Y Y N

Florida N Y N
Georgia Y Y* Y*

Guam N Y N

Hawaii Y Y N

Idaho N Y* Y*

Illinois N Y N

Indiana Y Y N

Iowa Y Y N

Kansas Y Y* Y*
Kentucky N Y* Y*

Louisiana Y Y N

Maine Y Y N
Maryland Y Y N

Massachusetts Y Y N
Michigan N Y N

Minnesota Y Y N
Mississippi Y Y N

Missouri Y Y N

Montana Y Y N

Nebraska Y Y N

Nevada Y N Y
New Hampshire Y Y N

### State Approved

State Program

(Y/N) a 

### State Regulations (Y/N) b 

### State adopted

40 CFR 280 (Y/N) c



### New Jersey N Y N

New Mexico Y Y N

New York N Y N

North Carolina Y Y* Y*

North Dakota Y Y N

Northern Mariana Islands N N Y

Ohio N Y N

Oklahoma Y Y N
Oregon N Y N
Pennsylvania Y Y N

Puerto Rico Y Y N

Rhode Island Y Y N

South Carolina Y Y N

South Dakota Y Y N

Tennessee Y Y N

Texas Y Y N
US Virgin Islands N N Y

Utah Y N Y

Vermont Y Y N
Virginia Y Y N
Washington Y Y N
West Virginia Y Y* Y*

Wisconsin N Y N

Wyoming Y Y N

a Y indicates Federally Approved state program. Some programs (e.g., Florida) have separate regulations even without an approved program.

b Y indicates state specific regul ations without explicit reference to 40 CFR 280. A Y*

indicates that state references 40 CFR 280 in its regulations and partially incorporates

them.

c Y indicates that 40 CFR 280 is either explicitly incorporated, unchanged, by state regulations, or that no state regulations exist. A Y* indicates that 40 CFR 280 is explicitly incorporated, but either with ex ceptions or additions specific to state regulations.Exhibit 2 – Summary of State Regulations and DeferralsStateEmergencyGeneratorUST ReleaseDetectionRequired(Y/N)Airport HydrantsDeferred from 40CFR 280 Subparts(Y/N)Field- ConstructedTanks Deferredfrom Subpart’s(Y/N)Spill Buckets/SumpsTightness TestingRequired (Y/N)BCDEGBCDEGAlabamaYPartialY N Y N YPartialY N Y N YYAlaskaYPartialN Y N N YPartialN Y N N YNAmericanSamoaNY Y Y Y Y YY Y Y Y Y YNArizonaYYY Y Y Y YYY Y Y Y YNArkansasNYY Y Y Y YYY Y Y Y YNCaliforniaYNN N N N NNN N N N NYColoradoNYY Y Y Y YYY Y Y Y YNConnecticutNYY Y Y Y YYY Y Y Y YNDelawareYPartialY Y Y N YPartialY Y Y N YYDistrict ofColumbiaYPartialY Y Y N YPartialY Y Y N YNFloridaNNN N N N NNN N N N NYGeorgiaNYY Y Y Y YYY Y Y Y YNGuamYNN N N N NNN N N N NNHawaiiNPartialY Y Y N YPartialY Y Y N YNIdahoYNN N N N NNN N N N NNIllinoisYPartial Y Y Y N YPartial Y Y N N YNIndianaNYY Y Y Y YYY Y Y Y YNIowaNYY Y Y Y YYY Y Y Y YNStateEmergencyGeneratorUST ReleaseDetectionRequired(Y/N)Airport HydrantsDeferred from 40CFR 280 Subparts(Y/N)Field- ConstructedTanks Deferredfrom Subpart’s(Y/N)Spill Buckets/SumpsTightness TestingRequired (Y/N)BCDEGBCDEGKansasNYY Y Y Y YYY Y Y Y YNKentuckyNYY Y Y Y YYY Y Y Y YNLouisianaNYY Y Y Y YYY Y Y Y YNMaineYNN N N N NNN N N N NNMarylandNNN N N N NNN N N N NYMassachusettsNNN N N N NNN N N N NYMichiganNYY Y Y Y YYY Y Y Y YNMinnesotaNYY Y Y Y YNN N N N NNMississippiNYY Y Y Y YYY Y Y Y YNMissouriNYY Y Y Y YYY Y Y Y YNMontanaYPartial Y Y Y N NPartial Y Y Y N NNNebraskaNYY Y Y Y YYY Y Y Y YNNevadaNYY Y Y Y YYY Y Y Y YNNew HampshireYNN N N N NNN N N N NYNew JerseyNNN N N N NNN N N N NNNew MexicoYYY Y Y Y YYY Y Y Y YNNew YorkYNN N N N NNN N N N NNNorth CarolinaNY Y Y Y Y YY Y Y Y Y YNNorth DakotaNYY Y Y Y YYY Y Y Y YNNorthernMariana IslandsNYY Y Y Y YYY Y Y Y YNOhioNPartial Y Y Y N YPartial Y Y Y N YYOklahomaNPartialY Y Y N YNN N N N NYOregonNYY Y Y Y YYY Y Y Y YNStateEmergencyGeneratorUST ReleaseDetectionRequired(Y/N)Airport HydrantsDeferred from 40CFR 280 Subparts(Y/N)Field- ConstructedTanks Deferredfrom Subpart’s(Y/N)Spill Buckets/SumpsTightness TestingRequired (Y/N)BCDEGBCDEGPennsylvaniaNNN N N N NNN N N N NYPuerto RicoYY Y Y Y Y YN N N N N NNRhode IslandYN N N N N NN N N N N NNSouth CarolinaNYY Y Y Y YYY Y Y Y YNSouth DakotaNN N N N N NN N N N N NNTennesseeNY Y Y Y Y YY Y Y Y Y YNTexasYN N N N N NN N N N N NNUS VirginIslandsNY Y Y Y Y YY Y Y Y Y YNUtahNYY Y Y Y YYY Y Y Y YYVermontYNN N N N NNN N N N NNVirginiaNYY Y Y Y YYY Y Y Y YNWashingtonYPartial N Y Y N NPartial N Y Y N NNWest VirginiaNY Y Y Y Y YY Y Y Y Y YNWisconsinYPartialY Y N Y YPartialY Y N Y YNWyomingYYY Y Y Y YYY Y Y Y YNTotal Yes21302811Total No35151845Total PartialNA1110NAExhibit 3. Field-Constructed and Emergency Generator USTs and Airport Hydrants By StateNote that total tanks in this exhibit exclude tanks on Tribal lands.State or TerritoryFuelServiceStationsa[1]USTs/Stationb[2]TotalActiveUSTsc[3]Not ServiceStationTanksd[4]=[3]-([1]*[2])FCTe[5]AHf[6]NuclearEGTg[7]EGT &Othersh[8]=[4]-([5]+[7])Alabama 6,200 2.65 18,885 2455 0 2 52450Alaska 566 2 1,151 19 4 6 015American Samoa14 2.65 16 5 0 0 05Arizona 2,000 2.65 7,003 1703 0 4 31700Arkansas 2,754 2.65 9,455 2157 0 0 22155California 9,970 2.65 37,498 11078 87 45 410987Colorado 2,183 2.65 7,949 2164 0 1 02164Connecticut 1,558 2.65 10,849 6720 0 0 26718Delaware 377 2.65 1,467 468 0 3 0468District of Columbia2134 2.65 696 341 0 0 0341Florida 9,217 2.65 28,862 4437 7 10 54425Georgia 8,215 2.65 30,049 8279 0 6 48275Guam242 2.65 267 156 33 0 0123Hawaii 344 2.65 1,692 780 24 7 0756Idaho 790 2.65 3,302 1209 0 2 01209Illinois 5,000 2.65 22,574 9324 0 1 119313Indiana 2,396 2.65 13,840 7491 0 1 07491Iowa 2,659 2.65 7,372 326 0 1 1325Kansas 2,800 2 6,967 1367 0 3 11366Kentucky 3,600 2.65 12,415 2875 0 3 02875Louisiana 3,650 2.65 12,601 2929 0 4 22927Maine 1,373 2 3,199 453 0 1 0453Maryland 2,339 2.65 9,243 3045 0 4 23043State or TerritoryFuelServiceStationsa[1]USTs/Stationb[2]TotalActiveUSTsc[3]Not ServiceStationTanksd[4]=[3]-([1]*[2])FCTe[5]AHf[6]NuclearEGTg[7]EGT &Othersh[8]=[4]-([5]+[7])Massachusetts 2,700 2.65 11,021 3866 0 5 13865Michigan 4,984 2.65 20,155 6947 0 3 46943Minnesota 3,649 2.65 14,532 4862 0 1 34859Mississippi 3,550 2 8,782 1682 0 3 11681Missouri 4,178 2 10,267 1911 0 16 11910Montana 4002.65 3,290 2230 0 1 02230Nebraska 1,486 2.65 6,903 2965 0 3 22963Nevada 1,169 2.65 3,669 571 0 5 0571New Hampshire 1,700 1 3,063 1363 0 2 11362New Jersey 3,301 2.65 16,830 8082 0 1 48078New Mexico 1,170 2.65 4,027 927 0 13 0927New York 6,700 2.65 28,897 11142 0 5 611136North Carolina 6,908 2.65 28,705 10399 0 20 510394North Dakota 922 2 2,163 319 0 4 0319Northern Mariana Islands118 2.65 68 20 0 0 020Ohio 4,935 2.65 22,998 9920 0 9 29918Oklahoma 3,250 2.65 11,102 2490 0 6 02490Oregon 1,696 2.65 6,112 1618 0 1 01618Pennsylvania 4,703 2.65 24,677 12214 0 3 912205Puerto Rico11,187 2.65 4,560 1414 0 0 01414Rhode Island 377 2.65 1,627 628 0 0 0628South Carolina 3,677 2.65 11,981 2237 5 3 72225South Dakota 1,053 2.65 3,021 231 2 4 0229Tennessee 4,650 2.65 17,105 4783 0 3 34780Texas 13,760 2.65 54,946 18482 4 8 418474US Virgin Islands137 2.65 144 46 0 0 046Utah 1,125 2.65 4,024 1043 0 2 01043State or TerritoryFuelServiceStationsa[1]USTs/Stationb[2]TotalActiveUSTsc[3]Not ServiceStationTanksd[4]=[3]-([1]*[2])FCTe[5]AHf[6]NuclearEGTg[7]EGT &Othersh[8]=[4]-([5]+[7])Vermont 646 2.65 3,067 1355 0 0 11354Virginia 4,650 2.65 20,600 8278 23 3 48251Washington 3,056 2.65 10,112 2014 50 11 11963West Virginia 1,300 2.65 5,696 2251 0 0 02251Wisconsin 3,919 2.65 13,725 3340 0 2 33337Wyoming 573 2.65 1,980 462 0 0 0462Totals 165,600627201 199,869 239 241 104 199,526SOURCES AND METHODSaEnergy Information Administration energy profiles.bEPA, Office of Underground Storage Tanks Information Collection Request (ICR), 2007. Note that in areas where the number of totalactive USTs are less that 2.65 * the numberof fuel service stations, the USTs per Station is calculated assuming the nearest integer (i.e.,2 or 1) that supports the number of stations.cEPA, End of Year UST Activity Report, 2007.dCalculated as total active USTs – (numberof Fuel Service Stations * USTs/Station).eInformation from DESC data.fInformation from DESC data and from FAA information on the locations of Class B airports.gEnergy Information Administration energy profiles.hCalculated as “not service station tanks” – the sum of field constructed USTs and Nuclear emergency generator tanks. AirportHydrant systems are not includedbecause their associated “tanks” were identified as ASTs.NOTES1Energy Information Administration does not maintain energy profiles for American Samoa, NorthernMariana Islands, Puerto Rico,and the U.S. Virgin Islands. The fuel service station USTs average about 31% of a state's total active USTs. PCCI used this averagepercentage of fuel service station USTs toestimate the number of emergency generatorUSTs in American Samoa, Northern MarianaIslands, Puerto Rico, and the U.S. Virgin Islands.2AOL Yellow Pages athttp://yellowpages.aol.com/gas-stations/dc/washingtonaccessed on 21 Jun 2008.3Guam Yellow Pages at http://www.informationpages.com accessed on 21 Jun 2008.AH- Airport HydrantEGT- Emergency Generator USTFCT- Field-Constructed UST

### Exhibit 4. State Field-Cons tructed UST Deferred Subparts

STATE Total

FCTs B C D E G

FCTs Not Deferred From Subpart Requirements

Alaska 4 4 4 4

California 87 87 87 87 87 87

Florida 7 7 7 7 7 7

Guam 33 33 33 33 33 33

Hawaii 24 24

South Carolina 5

South Dakota 2 2 2 2 2 2

Texas 4 4 4 4 4 4

Virginia 23

Washington 50 50 50 50

Total Not Deferred 239 187 133 137 211 183

Total Deferred 52 106 102 28 56

FCT- Field-Constructed UST

### Exhibit 5. State Airport Hydrant Deferred Subparts

Total

AHFS B C D E G

STATE AHFS Not Deferred From Subpart Requirements

Alabama 2 2 2

Alaska 6 6 6 6

Arizona 4

California 45 45 45 45 45 45

Colorado 1

Delaware 3 3

Florida 10 10 10 10 10 10

Georgia 6

Hawaii 7 7

Idaho 2 2 2 2 2 2

Illinois 1 1

Indiana 1

Iowa 1

Kansas 3

Kentucky 3

Louisiana 4

Maine 1 1 1 1 1 1

Maryland 4 4 4 4 4 4

Massachusetts 5 5 5 5 5 5

Michigan 3

Minnesota 1

Mississippi 3

Missouri 16

Montana 1 1 1

Nebraska 3

Nevada 5

New Hampshire 2 2 2 2 2 2

New Jersey 1 1 1 1 1 1

New Mexico 13

New York 5 5 5 5 5 5

North Carolina 20

North Dakota 4

Ohio 9 9

Oklahoma 6 6

### Total

AHFS B C D E G

Oregon 1

Pennsylvania 3 3 3 3 3 3

South Carolina 3

South Dakota 4 4 4 4 4 4

Tennessee 3

Texas 8 8 8 8 8 8

Utah 2

Virginia 3

Washington 11 11 11 11

Wisconsin 2 2

Total Not Deferred 241 107 92 98 136 102

Total Deferred 134 149 143 105 139



### AHFS- Airport Hydrant Fueling System

### Exhibit 6. Spill Bucket/Sumps Tightn ess Testing Requirement by State

State or Territory Total Active USTs Spill Buckets/Sumps Tightness Testing

Required (Y/N) Spill Buckets/Sumps Not Required to

be Tested

Alabama 18,885 Y

Alaska 1,151 N 1,151

American Samoa 16 N 16.00

Arizona 7,003 N 7,003

Arkansas 9,455 N 9,455

California 37,498 Y

Colorado 7,949 N 7,949

Connecticut 10,849 N 10,849

Delaware 1,467 Y

District of Columbia 696 N 696

Florida 28,862 Y

Georgia 30,049 N 30,049

Guam 267 N 267

Hawaii 1,692 N 1,692

Idaho 3,302 N 3,302

Illinois 22,574 N 22,574

Indiana 13,840 N 13,840

Iowa 7,372 N 7,372

Kansas 6,967 N 6,967
Kentucky 12,415 N 12,415

Louisiana 12,601 N 12,601

Maine 3,199 N 3,199
Maryland 9,243 Y

Massachusetts 11,021 Y

Michigan 20,155 N 20,155

Minnesota 14,532 N 14,532
Mississippi 8,782 N 8,782

Missouri 10,267 N 10,267

Montana 3,290 N 3,290

Nebraska 6,903 N 6,903

Nevada 3,669 N 3,669
New Hampshire 3,063 Y

New Jersey 16,830 N 16,830

New Mexico 4,027 N 4,027

New York 28,897 N 28,897

North Carolina 28,705 N 28,705

North Dakota 2,163 N 2,163

Northern Mariana Islands 68 N 68

Ohio 22,998 Y

Oklahoma 11,102 YState or Territory Total Active USTs Spill Buckets/Sumps Tightness Testing

Required (Y/N) Spill Buckets/Sumps Not Required to

be Tested

Oregon 6,112 N 6,112
Pennsylvania 24,677 Y

Puerto Rico 1 4,560 N 4,560

Rhode Island 1,627 N 1,627

South Carolina 11,981 N 11,981

South Dakota 3,021 N 3,021

Tennessee 17,105 N 17,105

Texas 54,946 N 54,946
US Virgin Islands 144 N 144

Utah 4,024 Y

Vermont 3,067 N 3,067
Virginia 20,600 N 20,600
Washington 10,112 N 10,112
West Virginia 5,696 N 5,696

Wisconsin 13,725 N 13,725
Wyoming 1,980 N 1,980

Totals 627,211 454,361

Tightness Test Cost per Bucket/Sump $100 - $400

Cost for Requiring Tests for Buckets/Sumps Currently Not Required to be Tested at $100/Test/Unit $45,436,100.00

Cost for Requiring Tests for Buckets/Sumps Currently Not Required to be Tested at $400/Test/Unit
$181,744,400.00

### Exhibit 7. Cost of Removing Subpart D Deferral for Emergency Generator USTs

Number of Emergency Generator USTs in U.S. 199, 526 Number of Emergency Generator USTs Currently Deferred from Release Detection Requirements in State UST Regulations 129,184 Cost of Removing Subpart D Deferr al For Emergency Generator USTs 129,184 USTs * $153 per UST – See Attachment 2 $19,716,487

### Exhibit 8. Cost of Removing Subparts B, C, D, E and G Deferrals for FieldConstructed USTs See Attachments 3 – 7 for supporting data

Number of Field-Constructed USTs in U.S. 239
Subpart B

Number of Field-Constructed USTs Currently Deferred from Subpart B-Related Design, Construction, Installation and Notification Requirements in State UST Regulations 52

Cost of Removing Subpart B Deferral/Year (52 * $367 per UST) $19,060 Subpart C

Number of Field-Constructed USTs Currently Deferred from Subpart C-Related General Operating Require ments in State UST Regulations 106

Cost of Removing Subpart B Deferral/Year (106 *$65 per UST) $6,889 Subpart D

Number of Field-Constructed USTs Currently Deferred from Subpart D-Related Release Detection Requirements in State UST Regulations 102

Cost of Removing Subpart D Deferral/Year (102 * $154 per UST) $15,719 Subpart E

Number of Field-Constructed USTs Currently Deferred from Subpart E-Related Release Reporting, Investigation, and Confirmation Requirements in State UST Regulations 28

Cost of Removing Subpart E Deferral/Year (28 * $259 per UST) $7,256 Subpart G

Number of Field-Constructed USTs Currently Deferred from Subpart G-Related Out-of-Service UST Systems and Closure Requirements in State UST Regulations (56 * $137 per UST) 56

Cost of Removing Subpart G Deferral/Year $7,677
Total Cost of Removing Subparts B, C, D, E and G Deferrals For FieldConstructed USTs $56,601

### Exhibit 9. Cost of Removing Subparts B, C, D, E and G Deferrals for Airport Hydrants See Attachements 8 – 12 for supporting data
Number of Airport Hydrants in U.S. 241 Subpart BNumber of Airport Hydrants Currently Deferred from Subpart BRelated Design, Construction, Installation and Notification Requirements in State UST Regulations 134

Cost of Removing Subpart B Deferral/Year (134 * $3 per hydrant) $350 Subpart C

Number of Airport Hydrants Currently Deferred from Subpart CRelated General Operating Require ments in State UST Regulations 149

Cost of Removing Subpart C Deferral/Year (149 * $142 per hydrant) $21,525
Subpart D

Number of Airport Hydrants Currently Deferred from Subpart DRelated Release Detection Require ments in State UST Regulations 143

Cost of Removing Subpart D Deferral/Year (143 * $176 per hydrant) $25,163 Subpart E

Number of Airport Hydrants Currently Deferred from Subpart ERelated Release Reporting, Inv estigation, and Confirmation Requirements in State UST Regulations 105

Cost of Removing Subpart E Deferral/Year (105 * $338 per hydrant) $35,457 Subpart G

Number of Airport Hydrants Currently Deferred from Subpart GRelated Out-of-Service UST Systems and Closure Requirements in State UST Regulations 139

Cost of Removing Subpart G Deferral/Year (139 * $0.6 per hydrant) $82
Total Cost of Removing Subparts B, C, D, E and G Deferrals For Airport Hydrants $82,577

## AttachmentsAttachment 1State UST Program Aproval Status and Regulations URL as of June 2008SPA(Y/N)Alabama YCHAPTER 335-6-15http://www.alabamaadministrativecode.state.al.us/docs/adem/McWord335-6-15.pdfAlaska N18 AAC 78.005http://www.legis.state.ak.us/cgi-bin/folioisa.dll/aac/query=[group+18+aac+78!2E005!3A]/doc/%7B@1%7D/hits_only?American Samoa Nhttp://www.epa.gov/oust/states/as.htmhttp://www.americansamoa.gov/departments/agencies/epa.htmArizona NTitle 49http://www.azleg.state.az.us/ArizonaRevisedStatutes.asp?Title=49Arkansas YRegulation 12http://www.adeq.state.ar.us/regs/files/reg12_final_071015.pdfCalifornia NTitle 23http://www.waterboards.ca.gov/water_issues/programs/ust/regulatory/docs/ccr_title23_2008.pdfColorado Y7 C.C.R. 1101-14http://oil.cdle.state.co.us/OIL/StatutesRegulations/Current Regs Jan 29 07.docConnecticut YSections 22a-449(d)-1, and Sections 22a-449(d) 101-113http://www.ct.gov/dep/lib/dep/regulations/22a/22a-449(d)-1through113.pdfDelaware YGeneral Requirements for USThttp://www.dnrec.state.de.us/dnrec2000/Divisions/AWM/ust/pdf/2008%20UST%20Regulations.pdfDistrict of Columbia YTitle 20 Environment UST Regulationshttp://doh.dc.gov/doh/frames.asp?doc=/doh/lib/doh/services/administration_offices/environmental/services2/ustd/pdf/allreg1.pdf&group=1813Florida NCHAPTER 62-761 USThttp://www.dep.state.fl.us/waste/quick_topics/rules/documents/62-761.pdfGeorgia Y391-3-15-.02http://rules.sos.state.ga.us/cgi-bin/page.cgi?g=GEORGIA_DEPARTMENT_OF_NATURAL_RESOURCES%2FENVIRONMENTAL_PROTECTION%2FUNDERGROUND_STORAGE_TANK_MANAGEMENT%2Findex.html&d=1Guam N10 GCA Chapter 76http://www.guamepa.govguam.net/regs/chapter76.htmlHawaii YHI UST Regulationshttp://hawaii.gov/health/environmental/waste/ust/rules.htmlIdaho N58.01.07http://adm.idaho.gov/adminrules/rules/idapa58/0107.pdfIllinois NPart 170http://www.state.il.us/osfm/PetroChemSaf/Current170code.pdfIndiana YIC 13-23 (IC 13-11) USThttp://www.ai.org/legislative/ic/code/title13/ar23/index.htmlIowa YChapter 135http://www4.legis.state.ia.us/Rules/Current/iac/567iac/e135/e135pp11.pdfKansas Y28-44http://www.kdheks.gov/pdf/regs/28-44.pdfKentucky NTanks Exempt from UST regshttp://www.waste.ky.gov/branches/ust/regs/Louisiana YUST-Reg-01http://www.deq.louisiana.gov/portal/LinkClick.aspx?link=UndergroundStorageTank%2fUST+Registration+Information+(2).pdf&tabid=2674Maine Yhttp://www.maine.gov/dep/rwm/ust/statutesrules.htmhttp://www.maine.gov/dep/rwm/ust/statutesrules.htmMaryland YUST Systems Compliance Outlinehttp://www.dsd.state.md.us/comar/subtitle_chapters/26_Chapters.htmMassachusetts Y527 CMRhttp://www.mass.gov/Eeops/docs/dfs/osfm/cmr/cmr_secured/527009.pdfMichigan NR 29.2101http://www.deq.state.mi.us/documents/deq-std-MUSTR.pdfMinnesota YChapter 7150http://www.pca.state.mn.us/publications/ust-rule-final.pdfMississippi YPart 280http://www.deq.state.ms.us/newweb/MDEQRegulations.nsf/3d9fe41da6b657cb86256d6e00638e7a/2b4929acd771bdb286256ba5004842a3?OpenDocumentMissouri Y10 CSR 20-10http://www.sos.mo.gov/adrules/csr/current/10csr/10c20-10.pdfMontanaYChapter 56http://www.deq.state.mt.us/dir/legal/Chapters/Ch56-toc.aspNebraska YTitle 159http://www.sfm.state.ne.us/regulations/title159.htmlNevada Y40CFR280http://ndep.nv.gov/bca/ust_reg.htm Adopted 40 CFR 280.New Hampshire YNH UST regs env-wm 1400http://www.des.state.nh.us/rules/env-wm1400.pdfNew Jersey NChapter 14Bhttp://www.state.nj.us/dep/srp/regs/ust/ustrule.pdfNew Mexico YTitle 20 Chapter 5 Part 5http://www.nmcpr.state.nm.us/nmac/parts/title20/20.005.0005.htmNew York Nhttp://www.dec.ny.gov/regs/4447.html#15662http://www.dec.ny.gov/regs/2490.htmlNorth Carolina Y15A NCAC 02N .0201http://reports.oah.state.nc.us/searchRules.asp?title=%2Fncac%2Ftitle+15a+-+environment+and+natural+resources&chapter=&searchCriteria=UST&returnType=ChapterNorth Dakota Y33-24-08http://www.legis.nd.gov/information/acdata/pdf/33-24-08.pdfNorthern Mariana Islands NCNMI UST Regulationshttp://deq.gov.mp/artdoc/Sec7art45ID101.pdfOhio N1301:7-9-01http://www.com.state.oh.us/sfm/pub/bust_1301_7-9.pdfOklahoma YTitle 165 Chapter 25http://www.occeweb.com/Divisions/PST/Forms/Rules/Chapter25.pdfOregon NUST General Permithttp://www.deq.state.or.us/regulations/rules.htmPennsylvania YChapter 245http://www.pacode.com/secure/data/025/chapter245/chap245toc.html#245.1.Puerto Rico YPuerto Rico UST Regulationshttp://www.jca.gobierno.pr/Enmiendas/ruleTAS.pdfRhode Island YRhode Island Ruleshttp://www.dem.ri.gov/pubs/regs/regs/waste/ustreg07.pdfSouth Carolina YChapter 61-92http://www.scstatehouse.net/coderegs/c061e.htm#61-92South Dakota YOperational Compliance Guidancehttp://legis.state.sd.us/rules/DisplayRule.aspx?Rule=74:56:01Tennessee YChapter 1200-1-15http://www.state.tn.us/sos/rules/1200/1200-01/1200-01-15.pdfTexas YTitle 30 Part 1 Chapter 334http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=334&sch=C&rl=YUS Virgin Islands NTitle 19 Chapter 56http://dpnr.gov.vi/dep/waste.htmUtah YUT UST R 311http://www.undergroundtanks.utah.gov/docs/ust_rules_091506.docVermont YUST Regulationshttp://www.anr.state.vt.us/dec/wastediv/ust/regs/fullUSTregs.pdfVirginia YVA UST Regulationshttp://www.deq.state.va.us/export/sites/default/tanks/pdf/usttech.pdfWashington YChapter 173 360http://www.ecy.wa.gov/pubs/wac173360.pdfWest Virginia YWV UST Regulationshttp://www.wvsos.com/csrdocs/pdfdocs/33-30.pdfWisconsin NChapter Comm 10http://www.legis.state.wi.us/rsb/code/comm/comm010.pdfWyoming YWQD rules Chapter 17http://deq.state.wy.us/wqd/WQDrules/Chapter_17.pdf1SPA- state program approvalState RegulationUST Regulation URLAttachment 2Emergency Generator USTs and Subpart D CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLabor Cost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponseor ActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87Cntr- $104States-$47Fac- $75Cntr- $89States-$47Fac- $38Cntr- $45States-$260.5 0.5 1 0 2 $164.50 $0.00 $0.00 48749 97498 $8,019,210.500.5 0.5 1 0 2 $164.50 $0.00 $0.00 682 1364 $112,189.000 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 6550 4257.5 $3,586,125.000 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 2357 1532.05 $1,290,457.500 0 1.67 0 1.67 $125.25 $733.00 0 1977 3301.59 $368,381.000 0 1.67 0 1.67 $125.25 $469.00 0 1977 3301.59 $324,887.000 0 0.6 0 0.6 $45.00 $384.00 0 45847 27508.2 $3,530,219.000 0 0.25 0 0.25 $18.75 0 $0.00 117893 29473.25 $2,210,493.750 0 0.05 0 0.05 $3.75 0 0 117893 5894.65 $442,098.750 0 1.5 0 1.5 $112.50 0 0 52397 78595.5 $5,894,662.500 0 0.02 0 0.02 $1.50 0 0 52397 1047.94 $78,595.500 0 0 1 1 $38.00 0 0 49431 49431 $1,878,378.00Subtotal205,707 $19,716,487.00Notes:Vapor MonitoringRecord results of monthly vapor monitoringGround-Water MonitoringConduct annual line tightness testRecord results of annual line tightness testLabor hours and rates and capital and O&M costs are from ICR 1360-08. Manual tank gauging with TTT and without TTT are standardbusiness practice and ATG is automated so no incremental cost per ICR 1360-08Automatic Tank GaugingMaintain records for specified time periodsRecord results of monthly ground-waterInterstitial MonitoringRecord results of monthly interstitial monitoringAlternative TechnologyRelease Detection for PipingConduct annual test of the operation of theautomatic line leak detector in accordance withthe manufacturer's requirementsRecord results of annual line leak detection testRelease Detection RecordkeepingPerform tank tightness testingManual Tank Gauging with Tank TightnessPerform tank tightness testingManual Tank Gauging Only (without TankTightness Testing)Subpart D, Release DetectionReading RegulationsInventory ControlRelease Detection for TanksReading Regulations One Time for ExistingFacilities1Attachment 2No of Subpart D deferred EG USTs 129184 No FCTs w inventory control and TTT 32748EG UST Population 199526No of TTTs/yr6550% Subpart D deferred 0.65 No FCTs w manual TG and TTT 11789New USTs/yr 2793No of TTTs/yr2358New USTsdeferred/yr1809 No FCTs w vapor monitoring and TTT 5240No Facilities w/new deferred FCTs682No of fac recording monthly VMs1977No Facilities w/exist. deferred FCTs48749 No FCTs w interstitial monitor 45847No of interstitial monitorings/month45847No of line leak detection tests/yr117893No of facility record maintain activities/yr49431No of line tightness tests52397No of ground water monitorings/yr1977EPA estimated 25% of existing and new USTs/yr use inventory control and TTT [p.56]. Using same estimate, 32,748 USTs ((129,184+1,808)(.25)) will result in6,550 TTTs/yr(32,748/5 yrs). Similarly using EPA estimates, 9%use manual tank gauging with TTT so 11,789 USTs ((130,992)(0.09)) will result in2,357 TTTs/yr(11,789/5 yrs). 4% use vapor monitoring so 5,240 USTs (130,992)(.04) will result inmonthly vapor monitorings for 1,977facilities(5,240 USTs/2.65). Same estimate method for ground-water monitoring resulting inmonthly ground-water monitorings for 1,977 facilities.35% of existing and new USTs use interstitial monitoring resulting in45,847 UST using this method((130,992)(.35)). EPA estimates 90% of facilities use pressure pipelines. Assuming same,117,893 USTs require line leakdetection tests((130,992)(.9)). EPA estimates 40% of facilities use line tightness tests. Assuming same,52,397 USTs require line tightness tests(130,992 USTs)(.4)).Existing and new facilities have to maintain records regardless of release detection method used, so49,431 facilities((130,992/2.65)) have to maintain records.EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 USTs [p.51, Table 2, ICR 1360-08].129,184 out of 199,526 generator USTs, 65%, are deferred from Subpart D type requirements instate regulations. Assuming same % of new generator USTs as EPA estimate,new generator USTs/yr = 1.4% of 199,706 = 2,793. Out of the 2,793 new generator USTs/yr, assume 65% or1,809 new generator USTs/yr willalso be deferred under state regulations. If EPA removes deferral of Subpart D, using EPA estimate of 2.65 UST/facility [p.51, Table 2],682 facilities/yr (1,808/2.65) will read regulations. 129,184 existing generatorUSTs or48,749 facilities (129,184/2.65) after deferral removal will have to read regulations once.2Attachment 3Field-Constructed USTs (FCTs) and Subpart B CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLabor Cost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 20 20 $1,645.000.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 1 $82.250 0.5 1 0.5 2 $137.50 $0.00 $0.00 1 2 $137.500 0 6 0 6 $450.00 $0.00 $1,410.00 10 60 $18,600.000 0 0 0.1 0.1 $3.80 0 $0.10 52 5.2 $202.800 0 0.5 0 0.5 $37.50 0 $0.43 1 0.5 $37.930.25 0.25 0.5 0.25 1.25 $91.75 0 $0.43 0 0 $0.00Subtotal69 $19,060.48Notes:Labor hours and rates and O&M costs are from ICR 1360-08.Number of Subpart B deferred FCTs 52 No FCTs Upgraded with int. linings 52FCT Population 239 No int. FCT inspections/yr 10% Subpart B deferred 0.22New FCTs/yr 3New FCTs deferred/yr 1No Facilities w/new deferred FCTs 0No Facilities w/exist. deferred FCTs 20Subpart B, Design, Construction, Installation, and NotificationCertification of InstallationReading RegulationsObtain and provide a certification of properinstallation on the notification formEPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08].52 out of 239 field-constructed USTs (FCTs), 22%, are deferred from Subpart B typerequirements in state regulations. Assuming same % of new FCTs in EPA estimate,new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 22% or1 new FCT/yr will be deferredunder state regulations. If EPAremoves deferral of Subpart B, assume the one facility (with new FCT)will read regulations.52 existing FCTs or 20 facilities (52/2.65) after deferral removal will have to read regulations once. Assume all FCTs havebeen upgraded by internal liningso10 FCTswill be inspected/yr(52 FCTs/5 yr = 10/yr).Assume 0 FCT sold/yr due to type of UST.Reading Regulations One Time for ExistingFacilitiesPrepare and submit forms within 30 days ofbringing an UST system into useNotify purchaser of an UST of owner's notificationobligationsPeriodic Lining InspectionsHave the line tank inspected within ten years afterlining and every five years thereafter- contractorMaintain recordsNotiifcation RequirementsPCCI assumes that all field-constructed USTs are constructed of steel with corrosion protection so removing deferral will not require site assessment by corrosion expert or maintaining records.1Attachment 4Field-Constructed USTs (FCTs) and Subpart C CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLabor Cost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 40 40 $3,290.000.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 1 $82.250 0.1 0.15 0 0.25 $19.95 0 $255.00 19 4.75 $5,224.050 0.1 0.15 0 0.25 $19.95 0 $0.00 33 8.25 $658.350 0 0 0.1 0.1 $3.80 0 $0.10 36 3.6 $140.400 0 1 0 1 $75.00 0 $0.00 3 3 $225.000 0.25 0.15 0.25 0.65 $42.50 0 $505.00 1 0.65 $547.500 0 0 0.1 0.1 $3.80 0 $0.10 3 0.3 $11.70Subtotal22 $6,889.25Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart C deferred FCTs 106 No of CP inspections/yr 19FCT Population 239 No of FCTs with IC systems 15% Subpart C deferred 0.44 No of facilities with IC systems 5New FCTs/yr 3 No of facility IC inspections /yr 33New FCTs deferred/yr 1 No of IC insp. record activities 36No Facilities w/new deferred FCTs 1 No of FCTs repaired/yr 3 (3% of new and existing deferred FCTs/year)No Facilities w/exist. deferred FCTs 40 No of Tightness Test/yr 1 (20% of repaired FCTs)Conduct inspection for impressed current cathodicprotection systems every 60 daysMaintain recordsSubpart C, General Operating RequirementsReading RegulationsOperation and Maintenance of Corrosion ProtectionHave a qualified tester conduct inspection for allcathodic protection systems within six months ofinstallation, at least every three years thereafter,and within six months of the repair of anycathodically protected systemReading Regulations One Time for ExistingFacilitiesMaintenance of Repair RecordsGather information on each repairEPA estimated 8,500 new USTs/yr for a base average total UST of 620,667 USTs (1.4% of base). [p.51, Table 2, ICR 1360-08]. 106out of 239 field-constructed USTs (FCTs), 44%, also deferred from Subpart C typerequirements in state regulations. Assuming same % of new FCTs as EPA estimate,new FCTs/yr = 1.4% of 239 = 3.Out of the 3 new FCTs/yr, assume 44% or1 new FCT/yrwill be deferred under state regulations. IfEPA removes deferral of Subpart C, assume theone facility (with new FCT) will read regulations.106 existing FCTs or 40 facilities (106/2.65) after deferral removal will have to read regulations once. EPAestimated that 45% of existing and new USTs will be protected by CP systems. [p.53, ICR 1360-08]. Using 45%, there will be16 CP system inspections/yr(((106 FCTs + 1 new FCTs)(0.45))/3 yrs). Also, EPA estimatedthat 3% of new and existing USTs will be tested within 6 months of repair. Using same estimate,3 FCTs will be tested within 6 months of repair((106 FCTs + 1 new FCT)(.03)).Number of CP tests/yr is 19 tests/yr(16Facilities with impressed current systems have to maintain last 3 CP inspection results or 17 records/yr ((33)(3/6)) and together with the 19 CP system inspection records/yr,the total associated records is 36/yr. EPAestimated 3% of new and existing USTs will be repaired/yr.Assuming same, 3 FCTs/yr will have to be repaired((107)*.03).Conduct tightness testing 30 days after repairMaintain recordsEPA estimated that 30% of USTs with CP systems will be protected with impressed current systems [p.53, ICR 1360-08]]. Using 30%, there will be15 FCTs with impressed current systems((107)(.45)(.3)) among6facilities(15 FCTs/2.65 FCTs/facility).Number of impressed current tests/yr is 33 tests/yr((15/2.65)*6).1Attachment 5Field-Constructed USTs (FCTs) and Subpart D CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.5 0.5 1 0 2 $164.50 $0.00 $0.00 38 76 $6,251.000.5 0.5 1 0 2 $164.50 $0.00 $0.00 1 2 $164.500 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 5 3.25 $2,737.500 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 2 1.3 $1,095.000 0 1.67 0 1.67 $125.25 $733.00 0 2 3.34 $372.670 0 1.67 0 1.67 $125.25 $469.00 0 2 3.34 $328.670 0 0.6 0 0.6 $45.00 $384.00 0 36 21.6 $2,772.000 0 0.25 0 0.25 $18.75 0 $0.00 93 23.25 $1,743.750 0 0.05 0 0.05 $3.75 0 0 93 4.65 $348.750 0 1.5 0 1.5 $112.50 0 0 41 61.5 $4,612.500 0 0.02 0 0.02 $1.50 0 0 41 0.82 $61.500 0 0 1 1 $38.00 0 0 39 39 $1,482.00Subtotal164 $15,718.83Notes:Subpart D, Release DetectionReading RegulationsInventory ControlRelease Detection for TanksReading Regulations One Time for ExistingFacilitiesPerform tank tightness testingManual Tank Gauging with Tank TightnessPerform tank tightness testingManual Tank Gauging Only (without TankTightness Testing)Automatic Tank GaugingMaintain records for specified time periodsRecord results of monthly ground-waterInterstitial MonitoringRecord results of monthly interstitial monitoringAlternative TechnologyRelease Detection for PipingConduct annual test of the operation of theautomatic line leak detector in accordance withthe manufacturer's requirementsRecord results of annual line leak detection testRelease Detection RecordkeepingVapor MonitoringRecord results of monthly vapor monitoringGround-Water MonitoringConduct annual line tightness testRecord results of annual line tightness testLabor hours and rates and capital and O&M costs are from ICR 1360-08. Manual tank gauging with TTT and without TTT are standardbusiness practice and ATG is automated so no incremental cost per ICR 1360-08.1Attachment 5No of Subpart D deferred FCTs 102 No FCTs w inventory control and TTT 26FCT Population 239No of TTTs/yr5% Subpart D deferred 0.43 No FCTs w manual TG and TTT 9New FCTs/yr 3No of TTTs/yr2New FCTs deferred/yr 1 No FCTs w vapor monitoring and TTT 4No Facilities w/new deferred FCTs 1No of fac recording monthly VMs2No Facilities w/exist. deferred FCTs 38 No FCTs w interstitial monitor 36No of interstitial monitorings/yr36No of line leak detection tests/yr93No of facility record maintain activities/yr39No of line tightness tests41No of ground water monitorings/yr2EPA estimated 25% of existing and new USTs/yr use inventory control and TTT [p.56, Table 4, ICR 1360-08]. Using same estimate,26 FCTs ((102+1)(.25)) will result in5 TTTs/yr(26/5 yrs). Similarly using EPAestimates, 9% use manual tank gauging with TTT so 9 FCTs ((103)(0.09)) will result in 2TTT/yr(3/5 yrs). 4% use vapor monitoring so 4 FCTs (103)(.04) will result inmonthly vapor monitorings for 2 facilities(4FCTs/2.65). Same estimate method for ground-water monitoring resulting inmonthly ground-water monitoringd for 2 facilities.EPA estimated that 35% of existing and new USTs use interstitial monitoring resulting in 36 FCTs using this method ((103)(.35))and36 monthly interstitial monitorings. EPA estimates 90% of facilities use pressurepipelines. Assuming same,93 FCTs require line leak detection tests((103 FCTs)(.9)). EPA estimates 40% of facilities use line tightness tests. Assuming same,41 FCTs require line tightness tests(103 FCTs)(.4)).Existing and new facilities have to maintain records regardless of release detection method used, so39 facilities((103/2.65 FCTs/facility)) have to maintain records.EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 USTs [p.51, Table 2, ICR 1360-08].102 out of 239 FCTs, 43%, are deferred from Subpart D type requirements in stateregulations. Assuming same % of new FCTs as EPA estimate,new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 43% or1 new FCT/yr will also be deferredunder state regulations. If EPA removesdeferral of Subpart D, assumeone facility (with the 1 new FCT) will read regulations.102 existing FCTs or 38 facilities (102/2.65) after deferral removal will have to read regulations once.2Attachment 6Field-Constructed USTs (FCTs) and Subpart E CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLabor Cost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 0 0 11 11 $904.750.25 0.25 0.5 0 1 $82.25 0 0 1 1 $82.250 1 4 0 5 $387.00 0 $2,653.00 1 5 $3,040.000 5 31 15 51 $3,954.00 0 $0.00 1 51 $3,954.000 0.25 0 0 0.25 $21.75 0 $0.43 1 0.25 $22.180 0.5 0 0 0.5 $36.50 0 $3.00 2 1 $79.000 0.5 0 0 0.5 $36.50 0 $3.00 2 1 $79.00Subtotal59 $7,256.43Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart E deferred FCTs 28No of facility suspect release/yr1FCT Population 239No of facility determine release/yr1% Subpart E deferred 0.12New FCTs/yr 3New FCTsdeferred/yr0No Facilities w/new deferred FCTs0No Facilities w/exist. deferred FCTs11Subpart E, Release Reporting, Investigation, and ConfirmationReport fill or overfill within 24 hours if over 25gallons or the reportable quantityNotify the implementing agency if unable tocleanup a spill less than 25 gallons or thereportable quantityReading RegulationsReporting of Suspected ReleasesReport the suspected releaseReporting and Cleanup of Spills and OverfillsGather information - FacilityGather information - ContractorReading Regulations One Time for ExistingFacilitiesBased on historical release records, EPA estimated that 12,500 owners and operators out of 237,533 or 5% will suspect release (12,500/237,533) [p.56, ICR 1360-08]. Using same estimate, 1 FCT facility/yr will suspectrelease from FCTs ((11)(.05)). EPA estimated further that 80% of facilities suspecting releases will determine that a release has occurred. Using same estimate, less than 1 orassume 1 FCT facility/yr will determinethat release has occurred.Assume 1 FCT/yr will notify implementing agency.EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08].28 out of 239 field-constructed USTs (FCTs), 12%, are deferred from Subpart E typerequirements in state regulations. Assuming same % of new FCTs as EPA estimate,new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 12% or 0new FCTs/yrwill also be deferred under stateregulations;assume 1 new FCT/yr. If EPA removes deferral of Subpart E, using EPA estimate of 2.65 UST/facility [p.51, Table 2],1 facility/yr (1/2.65 = 0.4 or 1) will read regulations.28 existing FCTs or 11facilities (28/2.65) after deferral removal will have to read regulations once.1Attachment 7Field-Constructed USTs (FCTs) and Subpart G CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts perActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 0 0 21 21 $1,727.250.25 0.25 0.5 0 1 $82.25 0 0 1 1 $82.250 0.25 0 0 0.25 $21.75 0 $3.00 1 0.25 $24.750 2.75 0 0 2.75 $239.25 0 $2,333.00 1 2.75 $2,572.250 6 40 18 64 $4,994.00 0 $0.00 1 64 $4,994.000 0 0 0.1 0.1 $3.80 0 $0.10 1 0.1 $3.900 0 0 0.5 0.5 $19.00 0 $3.00 0 0 $0.00Subtotal68 $7,677.15Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of SubpartG deferred FCTs 56 No of FCTs closed/yr 1FCT Population 239% Subpart G deferred 0.23New FCTs/yr 3New FCTs deferred/yr 1No Facilities w/new deferred FCTs 0No Facilities w/exist. deferred FCTs 21EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08].56 out of 239 field-constructed USTs (FCTs), 23%, also deferred from Subpart G typerequirements in state regulations. Assuming same % of new FCTs as EPA estimate,new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 23% or1 new FCT/yr will also be deferred under stateregulations. If EPA removes deferral of Subpart G, using EPA estimate of 2.65 UST/facility [p.51, Table 2],assume 1 facility/yr (1/2.65 = 0.3 or 0) will read regulations. 56 existing FCTs or21 facilities (56/2.65)after deferral removal will have to read regulations once.EPA estimated that facilities will close 16,500 USTs out of 629,167 USTs or3% each year [p.51, Table 2]. Using same estimate,facilities will close 1 FCT/yr((56+1)(.03)/2.65);however, this may not be a reasonableassumption for FCTs. Assume that only large facilities have FCTs and can maintain records on site.Mail records to implementing agency if they cannotbe maintained on sitePermanent Closure and Change-In-ServiceNotificationNotify the implementing agency of permanentclosure or change-in-serviceConduct site assessment of excavation zone -FacilityConduct site assessment of excavation zone -Contr.Subpart G, Out-Of-Service UST Systems And ClosureReading RegulationsClosure RecordsMaintain records after permanent closure orchange-in-service for at least three yearsReading Regulations One Time for ExistingFacilities1Attachment 8Airport Hydrant and Subpart B CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts perActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 134 134 $11,021.500.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 1 $82.250 0.5 1 0.5 2 $137.50 $0.00 $0.00 1 2 $137.500 0 0.5 0 0.5 $37.50 0 $0.43 1 0.5 $37.930.25 0.25 0.5 0.25 1.25 $91.75 0 $0.43 1 1.25 $92.18Subtotal5 $349.86Notes:Labor hours and rates are from ICR 1360-08.No of Subpart B deferred Hydrants 134Hydrant Population 241% Subpart B deferred 0.56New Hydrants/yr 1New Hydrants deferred/yr 0Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility.Subpart B, Design, Construction, Installation, and NotificationCertification of InstallationReading RegulationsObtain and provide a certification of properinstallation on the notification formReading Regulations One Time for ExistingFacilitiesPrepare and submit forms within 30 days ofbringing a hydrant system into useNotify purchaser of a hydrant system of owner'snotification obligationsNotiifcation Requirements1Attachment 9Airport Hydrant and Subpart C CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts per ActivityO&M Costs/ActivityNo. ofResponse orActivityTotal Hours/YearTotal Cost/YearFac- $92 CntrNA States-$47Fac- $87 Cntr-$104 States-$47Fac- $75 Cntr-$89 States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 149 149 $12,255.250.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 1 $82.250 0.1 0.15 0 0.25 $19.95 0 $255.00 55 13.75 $15,122.250 0.1 0.15 0 0.25 $19.95 0 $0.00 270 67.5 $5,386.500 0 0 0.1 0.1 $3.80 0 $0.10 0 $0.000 0 1 0 1 $75.00 0 $0.00 5 5 $375.000 0.25 0.15 0.25 0.65 $42.50 0 $505.00 1 0.65 $547.500 0 0 0.1 0.1 $3.80 0 $0.10 3 0.3 $11.70Subtotal88 $21,525.20Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart C deferred hydrants 149Hydrant Population 241% Subpart C deferred 0.62New Hydrants/yr 1New Hydrants deferred/yr 0Maintenance of Repair RecordsGather information on each repairAssume 1 new hydant system per year and 1 hydrant system per airport/airfield facility. Assume all hydrant systems are protected by CP systems. There will50 CP system inspections/yr((149+1)/3 yrs). Also, EPAestimated that 3% of new and existing USTs will be tested within 6 months of repair. Using same estimate,5 hydrants will be tested within 6 months of repair((149+ 1)(.03)).Number of CP tests/yr is 55tests/yr(50+5).Hydrant facilities with impressed current systems have to maintain last 3 CP inspection results or 22 records/yr ((45)(3/6)) and together with the 55 CP system inspection records/yr,the total associated records is77/yr. EPA estimated 3% of new and existing USTs will be repaired/yr. Assuming same,5 hydrants/yr will have to be repaired((150)*.03).Conduct tightness testing 30 days after repairMaintain recordsEPA estimated that 30% of USTs with CP systems will be protected with impressed current systems [p.53, ICR 1360-08]. Using 30%,there will be45 hydrants with impressed current systems((150)(.3)).Numberof impressed current tests/yr is 270 tests/yr((45)*6).Conduct inspection for impressed current cathodicprotection systems every 60 daysMaintain recordsSubpart C, General Operating RequirementsReading RegulationsOperation and Maintenance of Corrosion ProtectionHave a qualified tester conduct inspection for allcathodic protection systems within six months ofinstallation, at least every three years thereafter,and within six months of the repair of anycathodically protected systemReading Regulations One Time for ExistingFacilities1Attachment 10Airport Hydrant and Subpart D CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts perActivityO&M Costs/ActivityNo. ofResponseor ActivityTotal Hours/YearTotal Cost/YearFac- $92Cntr- NAStates-$47Fac- $87Cntr- $104States-$47Fac- $75Cntr- $89States-$47Fac- $38Cntr- $45States-$260.5 0.5 1 0 2 $164.50 $0.00 $0.00 143 286 $23,523.500.5 0.5 1 0 2 $164.50 $0.00 $0.00 1 2 $164.500 0 0.25 0 0.25 $18.75 0 $0.00 144 36 $2,700.000 0 0.05 0 0.05 $3.75 0 0 144 7.2 $540.000 0 1.5 0 1.5 $112.50 0 0 144 216 $16,200.000 0 0.02 0 0.02 $1.50 0 0 58 1.16 $87.000 0 0 1 1 $38.00 0 0 144 144 $5,472.00Subtotal406 $25,163.50Notes:Labor hours and rates are from ICR 1360-08.No of Subpart D deferred Hydrants 143Hydrant Population 241% Subpart D deferred 0.59New Hydrants/yr 1New Hydrants deferred/yr 0144 hydrants require annual line leak detection tests and line tightness tests .Existing and new facilities have to maintain records regardless of release detection method used, so 144hydrant facilitieshave to maintain records.Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility.Conduct annual line tightness testRecord results of annual line tightness testMaintain records for specified time periodsRelease Detection for HydrantConduct annual test of the operation of theautomatic line leak detector in accordancewith the manufacturer's requirementsRecord results of annual line leak detectiontestRelease Detection RecordkeepingSubpart D, Release DetectionReading RegulationsReading Regulations One Time forExisting Facilities1Attachment 11Airport Hydrant and Subpart E CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts perActivityO&M Costs/ActivityNo. ofResponseor ActivityTotal Hours/YearTotal Cost/YearFac- $92Cntr- NAStates-$47Fac- $87Cntr- $104States-$47Fac- $75Cntr- $89States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 0 0 105 105 $8,636.250.25 0.25 0.5 0 1 $82.25 0 0 1 1 $82.250 1 4 0 5 $387.00 0 $2,653.00 5 25 $15,200.000 5 31 15 51 $3,954.00 0 $0.00 5 255 $19,770.000 0.25 0 0 0.25 $21.75 0 $0.43 4 1 $88.720 0.5 0 0 0.5 $36.50 0 $3.00 4 2 $158.000 0.5 0 0 0.5 $36.50 0 $3.00 4 2 $158.00Subtotal286 $35,456.97Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart E deferred Hydrants 105Hydrant Population 241% Subpart E deferred 0.44New Hydrants/yr 1New Hydrantss deferred/yr 0Subpart E, Release Reporting, Investigation, and ConfirmationReport fill or overfill within 24 hours if over25 gallons or the reportable quantityNotify the implementing agency if unable tocleanup a spill less than 25 gallons or thereportablequantityReading RegulationsReporting of Suspected ReleasesReport the suspected releaseReporting and Cleanup of Spills andOverfillsGather information - FacilityGather information - ContractorReading Regulations One Time forExisting FacilitiesBased on historical release records, EPA estimated that 12,500 owners and operators out of 237,533 or 5% will suspect release (12,500/237,533) [p.56, ICR 1360-08]. Using same estimate,5 hydrantfacility/yr will suspect release from FCTs((105+1)(.05)). EPA estimated further that 80% of facilities suspecting releases will determine that a release has occurred. Using same estimate,4hydrants/yrwill determine that release has occurred and will notifyimplementingagency.Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility.1Attachment 12Airport Hydrant and Subpart G CostsLegal Hours ManagerialhoursTechnicalHoursClericalHoursResponseHours/ActivityLaborCost/ActivityCapital/StartupCosts perActivityO&M Costs/ActivityNo. ofResponseor ActivityTotal Hours/YearTotal Cost/YearFac- $92Cntr- NAStates-$47Fac- $87Cntr- $104States-$47Fac- $75Cntr- $89States-$47Fac- $38Cntr- $45States-$260.25 0.25 0.5 0 1 $82.25 0 0 139 139 $11,432.750.25 0.25 0.5 0 1 $82.25 0 0 1 1 $82.250 0.25 0 0 0.25 $21.75 0 $3.00 0 0 $0.000 2.75 0 0 2.75 $239.25 0 $2,333.00 0 0 $0.000 6 40 18 64 $4,994.00 0 $0.00 0 0 $0.000 0 0 0.1 0.1 $3.80 0 $0.10 0 0 $0.000 0 0 0.5 0.5 $19.00 0 $3.00 0 0 $0.00Subtotal1 $82.25Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart G deferred Hydrants 139 No of Hydrants closed 0Hydrant Population 241 each year% Subpart G deferred 0.58New Hydrants/yr 1New Hydrants deferred/yr 0Subpart G, Out-Of-Service UST Systems And ClosureReading RegulationsClosure RecordsMaintain records after permanent closure orchange-in-service for at least threeyearsReading Regulations One Time forExisting FacilitiesAssume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility.Mail records to implementing agency if theycannot be maintained on sitePermanent Closure and Change-InService NotificationNotify the implementing agency ofpermanent closure or change-in-serviceConduct site assessment of excavation zone- FacilityConduct site assessment of excavation zone- Contr.1

# PUBLIC WORKS TECHNICAL BULLETIN 420-49-36

15 June 2001

LEAK DETECTI O N

### Public W o rks Technical Bulletins are published by the U.S. Arm y Corps of Engineers, W a shington, D C . They are intended to provide

inform ation on specific topics in ar ea s of Facilitie s Engineering and

Public W o rks. They are not in tended to establish new DA pol icy.

### DEPARTM E NT OF THE ARMY

U.S. Ar m y Corps of Engineers 441 G Street, NW Washington, DC 20314-1000

CEMP-R

Public W o rks Technical Bulletin 15 June 2001

No. 420-49-36

FACILITIES ENGINEERING

UTILITIES

LEAK DET E CTION

1. Purpose . The purpose of this Public Works Tec hnical Bulletin (PW T B) is to tr ansm it

current inform ation on active and passive leak de tection technology for water, fuel, energy pipe and storage tank system s for im ple m e n tation at Army installations.

2

. A p p l i c a b i l i t y . This PW TB applies to all U.S. Arm y Public W o rks activities invo lv ing the use of water, fuel, energy pipe and storage tank system s.

3

. R e f e r e n c e s

. a. AR 420-49-02, Facilities Engine ering Utility Services, 28 May 1997.

b. Ar m y Re gulation (A R) 200-1, Environm en tal Protection and Enhancem ent, 21 February

1997. c. U.S. Code of Federal Regulation s (CFR ), Title 40, Part 280 , T echnical Standards and Corrective Action Requ irem ents for Owners a nd Operators of Underground Storage Tanks (UST), Vo. 53, No. 185, 23 Septem ber 1988.

4

. D i s c u s s i o n

.

a. The consequ e nces of utility sys t em leaks are m o re noticeable n o w than in the past

because of increas ing requirem e nts for envir onm ental p r otection and em phasis on energy and water conservation. Leaks of fuels, other petrol eum products and chem icals are a serious hazard. Leaks in water distribution system s waste water, energy and system capacity. Unfortunately it is not unusual for a water distribution system to have leakage rates of 20%. These factors highlight the growing impor tance of leak detection.

b. This PW TB provides an evaluation of cu rrent leak detection t echnology applicable to water, fuel and energy pipe system s and provide s lessons learned. The lessons provide insights

into se lec tio n of appropriate l eak detection technologies, insta lled eith er as post-construction
system additions or during construction. The a ttached document provides detailed inf o rm ation on the leak detection technology and application.

### PW TB 420-49-36

15 June 2001

5. Point of Contact . Questions and/or comments regarding this subject should be directed to

the technical POC:

U.S. Ar m y Engineer Resear ch and Developm ent Center Construction Engineeri ng Research Laboratory ATTN: CEERD-CF-M (Dr. Vincent Hock)

2902 Newmark Drive

Cha m paign, IL 61822-1072 Tel. (217) 373-6753 FAX: (217) 373-7222

e-m a il: v-ho ck@cecer. a rmy.m il

FOR THE COMMANDER:

DW IGHT A. BERANE K, P.E.

Chie f, Engineering and Construction Division

Directo r ate of Civil W o r k s Encl

2

# ACTIVE AND PASSIVE LEAK

DETECTION TECHNOLOGY FOR WATER, FUEL,

ENERGY PIPE AND STORAGE TANK

SYSTEMS

GUIDANCE

### ACTIVE AND PASSIVE LEAK DETECTIO N TECHNOLOGY FOR WATER, FUEL,

ENERGY PIPE AND STORAG E TANK SYSTEMS GUIDANCE

1. Introduction

A single gallon of gasoline can render a million gallons of water non-potable. The cost of effecting leak repairs is approxi mately proportional to the amount of trenching needed to access

the leak. Passive leak detection can provide leak location to within a 6 inch radius of the actual

leak location. The use of this technology can save critical tim e when detecting and locating a leak, and minimize unproductive trenching for repairs.

The U.S. Army maintains approximately 20,000 underground storage tanks (UST) and pressurized underground pipelines to store and deliver petroleum and other chemicals. According to the U.S. Environmental Protection Agency, approximately 25% of these are leaking. The average clean up cost of a petroleum leak is estimated by U.S. Army Toxic and Hazardous Materials Agency (USATHAMA) to be $193K , ranging higher where ground water is

contaminated.

The U.S. Army also maintains 3,000 miles of steam and High Temperature Hot Water (HTHW) distribution lines. A leak repair in these energy lines can cost in the range of $2-15K per leak, due in large part to the multiple trenching required to locate the source.

The objective of this PWTB is to publish lessons learned, based on the evaluation of passive leak detection technology applicable to water, fuel and energy pipe systems. The lessons provide insights into selection of appr opriate leak detection technolog ies, installed either as postconstruction system additions or during construction.

The U.S. Army Corps of Engineers has reported 1 

### that the most likely technology for reliable and cost effective detection of fuel leaks in underg round piping systems is manufactured by Arizona Instruments Inc., followed by the Tracer Rese arch ALD 2000 system (continuous monitoring), and finally the various cable systems (with the co nstraint that they must be installed in double walled piping systems).

Leak detection technologies applicable to wa ter and energy pipe systems were researched through vendor information, but no installed systems were found in the DoD.

2. Regulations The U.S. Naval Facilities Engineering Service Ce nter has reported upon the pertinent regulations that apply to petroleum leaks 2 

### . The key points are summarized here , please refer to the original

1 

### Timmins, J., Weber, R.A., Hock, V.F., Summary of Findings and Survey Results for Leak Detection Sensors for Water, Fuel and Energy Piping Systems , USACERL Report XX, 10 Sep 1997.

2 

### Lefave, J.P., Karr, L., Underground Pipeline Leak Detection and Location Technology Application Guide , Naval Facilities Engineering Service Center, Report UG-2028-ENV, April 1998.

### 2 report for a more detailed treatment of the regul atory subject as it appl ies to airport hydrant systems, USTs, ASTs, and their associated piping.

a. Federal Environmental Protection Agency Regulations

Federal regulations require >rel ease detection= for underground storage tanks (USTs) and their associated piping. Federal regulations also defer the release detection requirement indefinitely (Section 280.10 c and 280.10 d of Ref. 2 3 

### ) for field-constructed USTs, emergency power generator fuel tanks, and airport hydrant fuel distribution systems. Re lease detection methods that satisfy the Federal requirement for existing UST systems are discussed at Sections 280.41 and 280.43 (for tanks), and Secti on 280.44 (for piping) (Ref. 2 3 

### ). The options for release detection for pressu rized piping are:

(1) Automatic line leak detection (2) Annual line tightness testing (3) Monthly monitoring of soil vapo r, groundwater, or th e interstitial space of a double walled pipeline.

Automatic line leak detectors must be able to det ect leaks of 3 gallons per hour at a pressure of 10 psig within an hour. The annual tightness test must be able to detect a leak rate of 0.1 gallon per hour. Other methods are also allowed if they can detect a 0.2 gallon per hour leak rate, a release of 150 gallons in a month, or are approved by the implementing agency (Ref. 2 3 

### Section 280.43(h)).

b. State Regulations

Contacts at the State (or Territori al) regulating offices are availa ble to answer leak detection questions. A list of contacts can be found at http://www.epa.gov/OUST/states/statcon1.htm

. California, Florida, and Texa s have special leak detecti on requirements. California=s requirements are governed by the California Code of Regulations, Title 2 3, Sections 2640 et.seq. Florida=s requirements are governed by Florida Administrative Code, Rule 62-761, Underground Storage Tank Systems, and Ru le 62-762, Aboveground Storage Tank Systems. Texas= requirements are governed by th e Texas Administrative Code, Chapter 334, Underground and Aboveground Storage Tanks. Tabl e I provides a summary of the regulatory requirements for airport hydrant systems, USTs, ASTs, and their associated piping.

c. Regional Regulations

Certain localities may impose re gulations that differ from Fe deral and State requirements. Consult your local EPA office for more information on regional requirements.

3 

### U.S. Code of Federal Regulati ons (CFR), Title 40, Part 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST)

, Vo. 53, No. 185, 23 September 1988.

### Table I. Regulatory Requirements S u mmary (f

rom Ref. 4, L e fave an d Kar r ) 

### Airport Hydrant

y s t e m s S UST

and

Associated Pressuriz e d Piping AST

And Associated

Pressuriz e d Piping

Federal (Deferr e d) Sam e as tank (deferred for field constructed USTs); After 22 December 1998, secondar y containment (for pipi ng),

AND

Automatic Li ne Leak Detector required (3 g a l/hr at 10 psi g ). Option for approval of alternate re lease

detection methods. No require m e nt, unless piping is >10 percent of

total volum e, which

makes the ent i re sy stem a UST.

California Sam e as UST>> Hourly (3.0 gal/hr) when pressurized

AND

Monthl y (0.2 -gal/hr)

or Annual (0.1- g al/hr at 150 percent operating pre ssure) No require m e nt, unless piping is >10 percent of

total volum e, which

makes the ent i re sy stem a UST.

Texas Sam e as UST>> Hourly (0.2-gal/hr)

AND Annual Tight ness Test (0.1-gal/hr at 150 percent of operating pressure) << Same as UST.

Florida (Current

e g = s ) r Thru

1999 Sam e as UST >> Annual Tight ness Test << Same as UST.

After

1999 Sam e as UST >> In-Line Leak Detector (0.3-gal @ 10 psig)

OR Quarterly Pressure Test Hy drant & b u l k pro duct piping (3-inc h+

dia m eter.): < < sa me as USTs; Other piping upgrade with secondary

containment.

Florida (Proposed) Sam e as UST >> Annual Tight ness Test

OR Monthly Release D e tection sy stem Hy drant & b u l k pro duct piping: Annual tightness

test.



### 3

### 4 3. Technology Overview

There are eight main technologies in use for the detection of liquid leaks, each associated with physical phenomena which occurs either at a leak site or in the system due to the leak:

a. Gas sniffing systems detect changes in ch emical concentration, and require the leak to provide changes in concentra tion which are detectable above normal, naturally occurring

chemical levels.

b. Cable systems involve laying a cable in probable leak site s and monitoring for changes in the cable = s impedance, conductivity or (in the case of fiber optic cables) the refractive index, to determine when the cable comes in contact with a liquid.

c. Acoustic systems rely on noise produced by turbulent liquid flow through the leak to detect leaks in piping systems. Two sensors mounted either tem porarily or permanently to the pipe can locate the leak in relation to the sensors.

d. Infrared methods rely on the differen ce in temperature between the piping system and surrounding soil to provide a thermal signature which can be observed by special imaging equipment.

e. Magnetic flux leakage detection systems (also known as a > pigs = ) are instruments which identify and record information about pipeline anomalies such as corrosion pits, mechanical damage, dents, mill defects, wrinkle bends, hard spots, and hydrogen blisters. A pig must be launched with the pipeline comple tely evacuated and requires special launch and recovery stations.

f. Temperature compensated volumetric te sting systems measure the volume of liquid that must be added to a piping system to mainta in a constant pressure, thus providing the flow rate of a leak (or leaks) in gallons per hour.

g. Pressure point analysis systems detect pr essure waves caused by the sudden onset of a leak in a pipeline.

h. Supervisory Control and Data Acquisiti on (SCADA) systems rely on process control sensors to detect discrepancies in the performance of the system which could indicate a leak. One subset of the SCADA system category (which is often used as a stand-alone leak detection system) is Level Monitoring, which can be us ed only in closed systems which allow an accounting system to detect losses. The other SC ADA subsystem (which can also be used as a stand-alone system) is Mass Flow measuremen t methods, which rely on various physical phenomena to obtain accurate measurements of the total mass flow between two points on a pipeline. Irrespective of the portion of the SCADA system utilized as the detection system, each requires the use of a computer, sensor data acquisi tion, and an analysis algorithm to evaluate the sensor data and produce a leakage determination.

### 5 Each technology mentioned has a de tection sensitivity associated w ith the system it is used with. These eight technologies are ev aluated further in Appendix A in terms of the phenomena exploited, their system applicabil ity, and their advantages and disa dvantages when applied to the detection of leaks in a buried pipe system responsible for carrying liquids.

4. Technology Selection Criteria

Implementation of a leak detec tion and location (LDL) system is a tradeoff between cost and performance. Many variables should be consid ered when selecting LDL equipment. These

considerations are listed in Ta ble II and are discussed in this section. Further information on these LDL methods is contained in the Appendices of this report.

a. Soil Conditions: Soil conditions can affect LDL technology performance. For example, tracer gas migrates more quickly in dry, porous soil than in wet soil. Acoustic techniques may also be affected by the type ofsoil around the pipeline. Tidally influenced saltwater environments pose special corrosion probl ems for pipelines. When researching leak detection equipment, always consider the soil conditions.

b. Water Table: Some LDL techniques don = t work well if the pipeline runs below the water table or the high tide level. Tracer techni ques are less effective if the pipeline is under water, because leaking tracer gas may be washed away before it reaches a sensor. Or, the tracer may migrate and be detected by another sensor , thus indicating a leak in the wrong location.

c. Condition of Pipeline: The age a nd condition of a pipeline are important considerations when selecting leak detection equipment. Stat ic pressure testing techniques require modern high-quality valves, so that a l eaky pipeline can be distinguished from a leaky valve. Older small diameter pipelines contai ning sharp bends may be unsuitable for pigging.

d. Operations: Certain LDL techniques can be affected by routine operations. For example, temperature compensated pressure te sts must be conducted when a pipeline is > quiet = , which may require temporary suspension of operati ons. Acoustic techniques can be disturbed by vibrations generated from heavy traffic in the surrounding area. Pressure point analysis techniques may be hampered by fuel facility operations.

e. Time Monitoring: Some LDL met hods provide leak detection 24 hours a day (continuous monitoring). Other methods provide a > snap shot = , or assessment of the pipeline condition at that moment. Regulat ors may require that a snap s hot technique be employed at specified time intervals to implement an effective leak control program.

f. Spatial Resolution: Leak detection and location techniques provide different levels of spatial resolution. When properly applied, pi gging, cables, and ac oustic techniques can accurately locate leaks. However, the accuracy of tracer leak locati on is a function of the spacing between sampling points. Static pressure testing techniques don = t locate leaks at all. Sometimes the best way to solve leak detection problems is to first identify a leak with one technique, such as pressure testing, and then locate it with another technique, such as tracers.

### 6 g. Leak Rate Resolution: Some leak de tection techniques, such as temperature compensated pressure testing, provide a volumetri c measure of the leak rate. Other techniques, such as product sensitive cables, indicate where fu el has been detected, but not how much fuel is
present.

h. Ease of Retrofit: Most underground pipi ng systems have been in service for many years. It is therefore important to address whether a LDL technology can be applied to an existing pipeline. Some techniques, such as te mperature compensated pressure testing, can be easily applied on most pipelines, new or old. The hardware associated with these techniques is not an integral part of the pipeline system a nd can brought to the pipeli ne by a contractor who performs the test. However, these systems can be made a part of the fueling system, if that is

determined to be cost effective.

5. Cost Data

Table II. Cost Data for Surveyed Fiel d Installed Leak Location Systems (from Ref. 3, Timmins, Weber and Hock)

Leak Detection System Cost Data Source Installation Cost Equip. and Constr.

Materials Maintenance Cost (Annual) Length of Pipline in

feet Total Cost in

first Year Total Cost Per

Foot

Soil Sentry 12XP Pipeline and AST Environmental Monitoring System Site Costs Pensacola NAS (Based on 26,400') $274,000 $300 26,400 $274,300 $10.39

AZI Soil Sentry (Tracer Research Tracer Tightness used on storage Tanks - not included in cost data) Site Costs Ellsworth AFB (Based on 7908') $104,000 $40,000 $300 7,908 $144,300 $18.25

Soil Sentry 12XP Pipeline and AST Environmental Monitoring System Manufacturer Estimate (Based on 1000') $15,500 $10,750 $995 1,000 $27,245 $27.25

Tracer Research: ALD 2000 Manufacturer Estimate (Based on 5,000') $134,941 $25,883 5,000 $160,824 $32.16

Raychem: Trace Tek (Quote by Tracer Research) Manufacturer Estimate (Based on 5,000') $113,000 $8,000 5,000 $121,000 $24.20

PermAlert: PAL-AT Leak Detection System Manufacturer Estimate (Based on 5,000') $49,246 5,000 $49,246 $9.85

Vista Research: Model LT100 Manufacturer Estimate (Based on 1,000') $42,000 1,000 $42,000 $42.00

Hansaconsult: TCS Tightness Control System Manufacturer Estimate (Based on 1,000') and Converted

to US Dollars $66,000 1,000 $66,000 $66.00

Argus Technologies Manufacturer Estimate (Based on 5,280') $209,457 5,280 $209,457 $39.67



### This table was derived from questionnaires were to both installations and vendors to determine applicable current pricing on maintenance, instal lation, and materials costs for the system types being surveyed. Table II illustrates the rela tive breakdown of the cost data obtained. Vendors were supplied with a hypothetical piping system 1000 ft long, carrying JP-8 in a single wall pipe

### 7 buried 4 ft. beneath grade. DoD installations were asked to include similar system descriptions

with installation and maintenance cost data for their individual systems.

6. Implementation Guidance

To achieve sufficient performance from a leak detection system, the pipeline should first be verified for integrity before having a continuous monitoring system installed and tested. The leak detection system must also be relatively main tenance free and inexpensive to operate. None of the systems surveyed or researched provide th e optimal level of leak detection on their own. Leak detection in underground piping systems is a multifaceted problem, which requires several technologies to achieve a satisfactory solution.

The aspects of leak detection which are and will c ontinue to be the most critical are leak location and magnitude. A highly sensitive system which mon itors infrequently does little to protect the user from the high costs resu lting from a major discharge. A system which monitors continuously but is only able to detect major discha rge events puts the user at the same risk level.

Of the leak detection systems i nvestigated, the most promising t echnology for reli able detection of fuel leaks in underground fuel piping systems appears to be the gas sniffing systems. This technology has proven its ability to detect numerous hydrocarbons from natural gas, hydraulic fluid, or JP8. However, the system is not applicab le to water or energy pipe systems, and current systems are susceptible to water invasion.

The AZI leak detection and location system seems to have a good potential. It provides sufficient sensitivity to detect smaller leaks and has the ab ility to continuously monitor the piping system. The AZI system can also provide leak location to within 10 ft. with 20 ft. well spacing. The AZI system could be feasibly made impervious to water by the addition of the Argus Technologies proprietary sensor tube, whic h is selectively permeable. Because the AZI system draws a vacuum on the sensor tubing, the rate of diffu sion of concentrated hydrocarbons could be increased enough to reduce the idle time required, and still provide a system that continuously

monitors the site.

Tracer gas systems also have good potential. These systems are suitable for intermittent pipeline integrity tests and do not depend on prior knowledge of the pipeline condition. These systems are based on the detection of a unique marker gas intr oduced into the product car ried in the pipeline and detected through gas chromatography. They ar e not useful for potable water piping systems due to the toxicity of the marker gas.

The technology used in cable systems appear to be useful for both energy pipe systems and new potable water systems which incorporate double wall piping. There are also cables available for the detection of hydrocarbon liquids, which makes th is technology applicable to fuel, water, and energy pipe systems.

Table III lists the various leak detection and loca tion technologies discusse d in this bulletin, and

indicates their relative suitability to various field app lications under different conditions.Table III. LDL Suitabilityto ApplicationUtilityPotable WaterPetroleumHighTemp Hot WaterSewageMaterialBackfillWaterTablePressureMaterialBackfillWaterTablePressureMaterialBackfillWaterTablePressureMaterialBackfillWaterTableLDL Technology C a s t Iron T r an site C opper P l astic Steel Sand Grav el Cla y Be l o w Pi pe A bov e Pi pe Varies 0 – 1 0 ps i

A bov e 10 ps i A l um i n um Sand Grav el Cla y Be l o w Pi pe A bov e Pi pe Varies 0 – 1 0 ps i

A bov e 10 ps i Steel C opper Sand Grav el Cla y Be l o w Pi pe A bov e Pi pe Varies 0 – 1 0 ps i

A bov e 10 ps i Co nc r e te C a s t Iron Sand Grav el Cla y Be l o w Pi pe A bov e Pi pe VariesGas SniffingXXXXXXXXXXXXXXXXXXXXXXXCableXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXAcousticXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXInfraredXXXXXXXXXMagnetic FluxLeakageXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXTemp.CompensatedVolumetricXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXPressure Point AnalysisXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXSCADAXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX8

## APPENDIX A

Detailed Technology Descriptions

### Detailed T echnolog y Descriptions

1. Gas Sniffing

Technology: Electro-chem i cal sensors are calibrated to background concentration levels of the particular compound of i n terest. In som e situat ions this com pound can be an additive to the liquid to m a ke detection feasible . Sensors are located or transpor ted to a suspected leak location,

where read ings are taken and com p ared with thre shold valu es to dete rm ine eith er a > leak = or

> no leak = condition.

Use: These sensors are comm only used with Vo latile Organic Com pounds (VOCs) which produce highly localized concentrations of vapor wh en a leak occurs. Th ey can also be utilized with tracing gases, which are introduced into the system

.

Insta lla tion : Som e gas detection equipm ent can be installed perm anently and rem o tely monitored, however, the most frequent configur ation is a hand-held unit which is used in

surveys.

Advantages: This system is good for som e liquids, such as petroleum products, which produce vapor that can perm eate through the soil covering the pipe system and produce an area of

concentration sufficient for dete ction around the leak location.

Disadvantage s: Leaks of liquids with varying am bient co n centrations, such as water, can easily

be m a sked by the background noise. It is also not possible to chem ically detect the presence of a water leak without adding a m a rker com pound to the liquid. T h is would not be acceptable for potable water distribu tio n system s, as the tracing additives are som e ti m e s toxic.

2. Cable Systems

Technology:

(1) Im pedance Mism atch - A cable with a perm eable outer sh ield is excited w ith a known frequency. Becau se the dry cable has a kn own i m pedance and leng th, when a leak changes the dielectric properties at a particular location within th e cab le, it creates an impedance which can be located along the length of the cable by signal attenuation and phase

m easurem ents.

(2) Conductivity - Two conductors (general ly stainless steel) are woven into a specially treated cable or ribbon. W h en a conductive liquid form s a continuity path between the two wires, a leak condition is i ndicated and can s i gnal an alarm.

A1

### A2 (3) Refractive Index - A fiber optic cable is given a coating that interacts with a contaminant. In the presence of the contaminant, the light passi ng through the fiber is affected, providing a means of detecting and locating the contaminant.

Use: This technology is used to detect aqueous l eaks or (with special polymers) leaks of fuel, solvents, electrolytes, acids, and bases. The cable can be installed duri ng construction in limited access applications, or, as in the case of com puter room floors and other accessible areas,

installed after the fact.

Installation: The cable is installed in locations where leaking fluid is likely to accumulate. The cable is run along the bottom annulus of double walled pipe and terminated at monitoring stations. For area applications, the cable is laid in a serpentine pattern. In multi-branch pipe systems, individual cables can be run from branching junctions.

Advantages: This system can be sensitive to different types of liquids and ca n be easily installed. It can be used in piping systems as well as in storage tanks. The system presents a > leak = or > no leak = indication.

Disadvantages: After exposure to water or fuel, the cab le may need to be replaced. System design allows for false indications de pending on initial designed sensitivity.

3. Acoustic Methods

Technology: Acoustic leak detection methods rely on piezoelectric transd ucers to translate pressure waves generated by fluid escaping the pi ping system into an electrical signal. The system generally consists of a piezoelectric (a crystalline material which produces a voltage potential when stressed) transducer and an am plifier/signal conditioning unit. The operator then

makes a > leak = or > no leak = determination. Research is curre ntly investigating the permanent installation of transducers on a piping system at specific locations to continually monitor the

system = s condition.

Use: This technology can be applied to any system which is carrying fluids under pressure.

Installation: For permanent or semi-permanent instal lation, transducers are connected to piping junctions acoustically via waveguides (metallic c onnections which conduct vibrations efficiently from the pipe to the transducer). The monitoring system then acts as either a data logger or a remote unit, both of which maintain a record of the acoustic activity in the pipe system within acoustic range by storing the acousti c signals received above a set threshold in either volatile memory or by transmitting them to a central computer. Portable units are used in a search pattern over the piping system, which may include direct acoustic coupling to the system where it is accessible through manholes or vents.

Advantages : Leak location can be determined to within several feet or even within fractions of an inch, depending upon the location of the pipe and its surroundings. Because the system can be used to scan a piping system, the cost to detect a leak in a large system is only dependent on the man-hours required to cover the system.

### A3 Disadvantages: The system can give false positives due to flow noise around valves and other geometry changes. The system can also give fa lse negatives due to noise interference from the surroundings. Systems which depend upon operato rs to evaluate the signals require an experienced operator.

4. Infrared Imaging

Technology: Infrared inspections are performed w ith a video camera capable of recording infrared radiation. The camera records the temper ature differential and the images are processed to show the different temperatures in a color spec trum. Data can be videotaped for future review and processing.

Use: These systems are generally used on piping systems which ca n produce significant thermal signatures through several feet of earth. This limits them to use with piping systems which transport liquids sign ificantly above the su rrounding ambient ground temperature, such as heating water or steam.

Installation: These systems are used for surveys onl y. When conditions permit, the system or suspect locations within the system are scanned for leak indications.

Advantages: The advantages of this system are that it can be used to scan large areas at a time and does not require any excavation. The infrared technique is especially useful for surveying heating and cooling dist ribution piping systems.

Disadvantages: The disadvantages of this process ar e that it cannot be used for any piping system that does not present a temperature differential.

5. Magnetic Flux Leakage (Pigging)

Technology: Magnetic flux leakage detection is done w ith instruments which identify and record information about pipeline anomalies such as corrosion pits, mechanical damage, dents, mill defects, wrinkle bends, hard spot s, and hydrogen blisters. Magnetic flux is sent into the pipe by the pig, and anomalies cause leakage of the magn etic flux into the ground. Data is recorded for future review and processing.

Use: These systems are only used for piping syst ems which are made of steel or cast iron.

Anomalies can be located with an accuracy of + 0.1% of the distance measured, and the minimum detectable pit ranges from 5 to 10% of the pipe wall thickness.

Installation: These systems are used for surveys only. The magnetic tape produced by the pig is

examined for conditions associated with leaks.

Advantages: The advantages of this system are that it can be used to scan large areas at a time and does not require any excavation.

### A4 Disadvantages: A pig must be launched with the pipe line completely evacuated and requires special launch and recovery stations. Pipeline diameters and bend radii must be large enough to accommodate the pig.

6. Temperature Compensated Volumetric Testing

Technology: Temperature compensated volumetric tes ting systems measure the volume of liquid that must be added to a piping system to mainta in a constant pressure, thus providing the flow rate of a leak (or leaks) in gallons per hour. The temperature compensation is important, because thermally induced volume changes can either mask a small leak (causing mi ssed detection) or be mistaken for a small leak (causing a false alarm). T hus, this type of testing must not be confused as being the same as conve ntional pressure testing.

Use: This type of testing can be applied to any pi ping system, made of any material. It is also applicable to any type of liquid, be it aqueous or petroleum based.

Installation: The equipment must be plumbed into the piping system under test.

Advantages: The measurement is highly accurate, capable of finding leak rates of less than the regulatory limit of 0.1 gallon per hour.

Disadvantages: The measurement takes 2 hours to complete, and the piping system must be taken out of service during the m easuring period. Also, there is no way to determine the location

of the leak

7. Pressure Point Analysis

Technology: Pressure point analysis systems detect pressure waves caused by the sudden onset of a leak in a pipeline. Since this systems deals with the internal liquid, external factors such as ground water, previous contamina tion, or location of th e pipeline (above or below ground) have no effect on performance.

Use: This system can be applied to pressurized pipelines ranging fr om 3 to 42 inches in diameter, regardless of material of construc tion. It is also applicable to a ny type of liquid, be it aqueous or petroleum based.

Installation: The pressure detectors are plumbe d directly into the pipeline.

Advantages: The sensors can be spaced miles apart, unless special conditions like steep hills exist, when a sensor must be placed at the top of the hill.

Disadvantages: Flow noise can mask a leak indication (l eak detection limited to 0.5 to 2% of the flow), and normal operation (such a valve movement) can also imitate leaks. The size of the leak which can be detected also depends upon pipeline volume (0.05 gph leaks detectable in 5,000 gallon systems, 0.1 gph leaks detectable in 17,0 00 gallon systems, and 3.0 gph leaks detectable in 116,000 gallon systems).

### A5 8. SCADA Systems

Technology: Supervisory Control and Data Acqui sition (SCADA) systems use sensors to convert physical phenomena (such as pressure, temperature, flow rates, and density) into electronic signals which can be interpreted by the control syst em. SCADA systems rely on the combination of sensor inputs to determine the stat e of the system, which is then used to modify the control inputs to brin g the system (heat distribution, petr oleum delivery, etc.) to the desired state. Complete information about the liquid sy stem is precisely determined at the sensor

locations.

Use: SCADA systems control large networks of piping systems fo r the delivery of value-added liquids. These systems are monitored by a central processor, which uses the inputs from remote monitoring locations to account for the total volume of liquid. SC ADA is applicable to potable water distribution systems as well as hot water heat distribution and Heating Ventilation and Air Conditioning (HVAC) systems. The nature of the monitoring system allows the incorporation of volumetric leak detection, as well as energy l eak detection, over the entire piping network.

Installation: The multiplicity of the sensors required for an effective leak detecting SCADA system is easily implemented into new constr uction. Post-construction installation of a SCADA system limits sensor placement to accessible locations, when some, if not all, of the

aforementioned sensors can be in corporated into the leak de tection system, depending upon the particular installation requirements of each sensor . The sensors are then linked through telemetry to a central monitoring location a nd supervised by a host computer.

Advantages: The sensor inputs at adjacent measurement locations can be used to determine leak

locations as well as leak rates. The time frame required to detect and locate a leak in the system is dependent on the frequency with which the system is sampled.

Disadvantages: The cost of sensors and data communication equipment necessary for implementing a SCADA system on a la rge piping system is prohibitive.

9. Level Monitoring (SCADA sensor)

Technology: Level monitoring uses high precision st orage tank liquid level measurements to determine the volume of liquid contained in each tank of the system. In a closed system, the volume should be constant for a given pressure a nd temperature when there is no leak present in the system. Any variation in the level generates an alarm that so mething is out of specification for the system. Sensors can be float switches, of either capacitance or continuity type.

Use: Recirculating heating water distribution systems can recover and reuse water used to carry heat energy to the various dist ribution points. Also, any petrol eum distribution system which goes to a static state for suitable length of tim e would be a candidate fo r liquid level monitoring for leak detection. In general, a ny liquid piping system which can be held in a static state for a sufficiently long period of time (based on total sy stem volume), is a candi date for liquid level monitoring.

### A6 Installation: These systems can be designed into the construction of the system or added at a

later time. The installation of a level monitori ng system requires either a continuous reading probe or discrete level probe to be installed in each tank within the closed system, as well as the necessary monitoring wiring.

Advantages: The implementation of this system for leak detection is relatively inexpensive. Cost of implementation is directly rela ted to the accuracy required for th e particular system to detect leaks of a specific rate.

Disadvantages: Liquid level monitoring requires the system to be in a static state for a period of time which is dictated by the resolution of the sensors and th e volume of the system. A large volume system would require extremely precise m easurement sensors which would be subject to noise, or an excessively lengthy st atic state holding period to dete ct small leaks in the system.

10. Magnetic Induction Flow Meters (SCADA sensor)

Technology: Magnetic induction flow meters rely on th e conductive properties of the liquid. The flow passes through a magnetic field and this produces a voltage difference over the crosssection of the flow area. This voltage is propor tional to the (average) fl ow velocity. By knowing the conductivity of the liquid, the strength of the magnetic field, and the cross-sectional area, the flow velocity can then be determ ined by measuring the potential.

Use: Can be used for all liquids flowing in pipes, providing that the conduc tivity of the liquid is known. These sensors, as with all mass flow sensors, are generally used as an accounting system

to detect the loss of material between monito ring locations. These sensors can only identify the section of piping in wh ich there is a leak.

Installation: These sensors rely on precise flow meas urements for determining mass flow rates. The sensors are housed in a short section of pipe which is installed in the piping system atlocations where the system will maintain a positive pressure and flow continuity. For postconstruction installation, a secti on must be cut from the existing pipe, the exposed ends flanged, and the magnetic inductive monitoring section installed.

Advantages: The sensors are relatively inexpensive and are very accurate.

Disadvantages: There are velocity restrictions which depend on the liquid being pumped.

11. Calorimetric Flow Meters (SCADA sensor)

Technology: These flow sensors utilize the calorimetric principal to determine flow velocity at a certain point in the flow field. The flow is loca lly heated and then the temperature is sensed a short distance downstream. Based on the thermal permitivity (the temperature dependent rate at which thermal energy propagates through a given medium) of the material, the temperature

differential indicates the flow velocity. Assumptions on flow fi eld profile are then used to

calculate the volumetric flow rate from which the mass flow rate can be determined for a liquid of known density.

### A7 Use: Can be used for a wide range of viscositie s and for high solids content, as in sanitary applications.

Installation: These sensors operate using assumptions a bout the profile of the flow in the piping system, which are similar to the assumptions made for the magnetic inductive mass flow sensors. They are similarly housed to magnetic inductive sensors and must be installed in the same fashion. Because the temperature must be measured at at least one location, there are components

which are intrusive to the local flow field.

Advantages: Highly accurate flow detection.

Disadvantages: The main disadvantage is precisely c ontrolling the temperat ure at the sensor. Fouling of the sensor could be a problem, depending on the liquid being transported in the piping.

12. Ultrasonic Flow Meters (SCADA sensor)

Technology: By utilizing time-of-flight measurements of wave propagation or Doppler shift of the ultrasonic signal, the average flow veloc ity can be determined using two piezoelectric transducers, one a > sender = and the other a > receiver =

.

Use: Ultrasonic flow meters can be used for a wide range of mate rials from sewage to ammonia, nitrogen, natural gas, air, acids, heavy oils, or desalinated water.

Installation: These systems can be attached to the exte rior of the pipe in configurations which

minimize the effects of a non-uniform flow fiel d across the area being monitored. The location must correspond to a (preferably st raight) section of pipe, which wi ll maintain a consistent flow field during monitoring.

Advantages: The ultrasonic sensor systems have high measuring accuracy, no pressure loss or flow obstructions, low power consumption, and can be purchased in intrin sically safe versions for explosive environments. Disadvantages: The initial cost of the signal processing equipment can be prohibitive.Table A-I. Performance Characteristics of LDL Technologies(from Ref. 4, Lefave and Karr)ParameterTemperatureCompensatedPressure TestTracersPiggingSensitive CableFiber Optic CableAcoustic EmissionPressure PointAnalysisSoilConditionsNo Effect on LDLPerformanceWorks Best inHighly PermeableSoilsNo Effect on LDLPerformanceNo Effect on LDLPerformanceNo Effect on LDLPerformanceSensitive to theAcousticProperties of theSurrounding SoilNo Effect on LDLPerformanceWater TableNo Effect on LDLPerformanceHigh Water Tableand Saturated SoilsReduceEffectivenessNo Effect on LDLPerformanceSensitive to WaterIntrusion to CableSensitive to WaterIntrusion to CableSensitive SoilMoisture ContentNo Effect on LDLPerformanceCondition ofPipelineLeaking ValvesPrevent AccurateTestingNo Effect on LDLPerformanceNo Effect on LDLPerformanceNo Effect on LDLPerformanceNo Effect on LDLPerformanceNo Effect on LDLPerformanceLeaks Present atInstallation Will Not BeDetected.OperationsSensitive toFuelingOperationsTracer Gas Must BeDissolved in FuelThroughout PipelineNo Effect on LDLPerformanceNo Effect on LDLPerformanceNo Effect on LDLPerformanceSensitive to NoiseGenerated byFacility OperationsSensitive to Vibrationsand Fuel Operations atthe FacilityTimeMonitoringSnap ShotSnap ShotSnap ShotContinuousContinuousSnap ShotContinuousSpatialResolutionPoorDependent UponSample SpacingGoodGoodGoodGoodGoodLeak RateResolutionGoodLowLowLowLowLowGoodEase ofRetrofitEasyModerateDepends onConfiguration ofPipelineDifficultDifficultModerateEasy

### B1 

## APPENDIX B

Field Survey Results

Field Survey Results

Site visits resulted in the accumulation of a grea t deal of useful inform ation on the installation and operation of several commonly used leak de tection and location systems. The most common systems encountered were the ga s sniffing systems, configured either to det ect hydrocarbons directly or to detect the pres ence of trace levels of a marker gas. The other systems surveyed consisted of cable systems and volumetric SCADA type systems. To date, CERL has performed 8 site surveys:

1. Pensacola NAS [14 inch JP5 line monito red by an Arizona In struments hydrocarbon vapor detector], 2. Anchorage Airport [10 inch JP8 line mon itored by a Hansa Consult pressure step system], 3. Elmendorf AFB [2 inch mogas and diesel lin es monitored by Permalert cable systems], 4. North Island NAS [8 inch diesel line used in verification of a Vista Reasearch volumetric temperature compensation system], 5. Travis AFB [14 inch JP8 line monitored by an Argus Technologies hydrocarbon vapor detection system], 6. Ft. McCoy ANG [4 inch and 8 inch JP8 lines in a single conduit monitored by a Raychem cable system], 7. Whiteman AFB [18 inch JP8 line monitored by a Tracer Research marker gas system],

and 8. Ellsworth AFB [18 inch JP8 line monitore d by an Arizona Instruments hydrocarbon vapor detector].

Two leak detection systems manufactured by Ar gus Technologies were surveyed, and neither was functional. The system at Whiteman was ab andoned in favor of the Tracer Research system when the quoted repair price of the Argus sy stem exceeded the insta llation cost of the new Tracer Research system. The system installed at Travis AFB was installed concurrently with the pipeline to specifications by the pipeline cons truction contractor. MSgt . Torres indicated the system had yet to perform to the manufacturer = s specifications. The literat ure received from the company contained several performance evaluati on documents from both foreign and domestic organizations. The system is based on sound scien tific principals, however the system cannot be recommended due to two factors; 1) The time requi red for a given minimum leak to diffuse into the sensor requires the system to remain idle for so long that a leak of dangerous magnitude could remain undetected long enough to cr eate a significant spill and 2) the system = s apparently unreliable performance.

AZI systems were surveyed at two sites, Pens acola NAS and Ellsworth AFB. This system has proven itself in the field, with its major drawback being the susceptibility of the system to water

### invasion an d the resu lting inability to m onitor so m e sections of the piping system . In addition, experience has shown that the remote operation capabilities of the sys t em can be a liability

. Specifically, a lightn i ng strik e at th e Pensacola NAS disabled several monitoring stations for several days. Another drawback to the AZI sys t em is locating the leak source. At the Pensacola installation, the sensor tubes cove r 20 ft. of pipeline per sensor well - see Figure B-1. This m eans that a le ak indication ca n be loca ted to with in o n ly 20 f t . of its sou r ce. T h e dete ction levels f o r a given leak rate are also dependent on the insta lla tion of the system , particula r ly the backf i ll surrounding the sensor tubing and pipeline. AZI recomm ends a m i ni m u m percolation value that must be obtained by the backfill in order f o r

the system to p e rf orm to its m i nim u m concentr ation

detection levels. AZI claim s a lower detection lim it for gasoline of 150 ppm and 60 ppm for JP4, but does not give levels for either JP5 or JP8. Depending on soil types and ground water conditions, the system m a y be a vi able solution fo r detection of fuel l eaks, however, it is not applicable to water or energy pipe system s.

Figure B-1. AZ I Model Tw elve-X installa tion schemat i c

The Tracer Research s y stem was used at Trav is AFB before the ins t allation of the Argu s Technologies system . The Tracer system was consid ered too m a intenance intensiv e after several of the probe wells w e re dam a ged by constr uction and grounds m a intenance equipm ent. However, th e sam e type of wells are used at W h i t em an AFB and have not experienced the same

rate of attrition. The 20 ft. well spacing of the Tracer Research system allows leak location to within 10 ft. of the source by com p arison of rela tive concen tra tion leve ls. The deficiency of the Tracer Research sy stem is sim ilar to that of th e Argus Technologies system , in th at it is no t a

B2

### continuous monitoring s y stem . Leaks of dangerous m a gnitude can exist u ndetected until th e next scheduled testing date.

Two volumetric system s were surveyed - a pres su re differential system by Hansa Consult and a

tem p erature com p ensated volum etric system fro m Vista Research. T h e pressure differential
system samples the pressurized pi pe 75 tim es during a 20 m i nute test and then repeats at a higher pressure. Th e data is an alyzed by a PC and th e leak ra te is calcula ted. The system is able to
detec t a le ak ra te of 1.5 g a l/ hou r. The tem p erature com p ensated volum etric leak detection syste m from Vista Research utilizes a reservoir tank and precision m easure m ents of the tank level to produce a tem p erature com p ensated volum etric curv e at two different pr essu res. The testin g protocol requires about 2 hours to com p lete and is capable of de tecting leaks of 0.01 gal/hour.

Figure B-2. A temperature compen sate d volu m etric leak detection sy stem

Two cable system s were also surveyed, one by Perm alert and one by Raychem

. Both cable
system s were perform i ng as advertised and on e was ind i cating a wa ter leak con d ition. The

disadvan t ag e of the cable system s is that they require replacem ent of any length of cabling which

com e s in contact with liquid. Also, they m u st be installed in a conduit pipe, effectively negating their applicability for an existing system and incr easing th e in stallation co st of a new system . The cable system s are rank ed lowest in perform a nce and cost. Water intrusion is a m a jor prob lem for

B3

### cable system s and since the cables must be prot ected, their use is lim ited to double-walled piping
system s, which inc r ea se s the initia l cost of syste m installatio n and preve n ts re tro

- f itting exis ting
system s.

Figure B-3. Raychem TraceTek cable, typica l of those u s ed in a ca ble lea k detection
system

B4

### Appendix B1 

### MEMORANDUM

Date: August 26, 2008

To: Cho Yi Kwan, EPA/OUST Cindy Manson, Industrial Economics, Inc.

From: Dave Gustafson, Donovan Hannu, a nd Mary Blel, DPRA Incorporated

Re: Draft Preliminary Assessment of Baseline Conditions and Cost Impacts Associated with Regulating Spill Buckets and Sumps for UST Systems; DPRA WA 3971.0001.0025, Task 3

____________________________________________________________________________

I NTRODUCTION



### In 1984, Congress responded to the increasing threat to groundwater posed by leaking underground storage tanks (LUSTs) by adding Sub title I to the Resource Conservation and Recovery Act (RCRA). Subtitle I required EPA to develop a comprehensive regulatory program for underground storage tanks (USTs) storing petr oleum or certain hazardous substances. In 1988, EPA issued UST regulations covering three sections: technical re quirements, financial responsibility requirements, and state program approval objectives (see 40 CFR Parts 280 and 281).

EPA is currently exploring potential revisions to the existing UST regulations. Specifically, the Agency is considering amending current UST requirements to address four issues: (1) technical/administrative fixes; (2) deferred UST systems; (3) existing regulatory gaps; and (4) potential deregulatory options. Th is memorandum presents a prelim inary analysis that identifies and assesses potential cost impacts associated with implementing testing and leak detection requirements for spill buckets and sumps.

EPA is considering requiring periodic tightness testing for UST spill buckets and sumps, as well as requiring release dete ction (i.e., vapor monitoring) and re cordkeeping for these pieces of equipment. This cost impact analysis estimates the universe of USTs that will likely be affected, including estimating the associated number of spill buckets and sumps, assesses the potential costs to UST owners/operators as a result of requiring tightness testi ng and recordkeeping for spill buckets and sumps, and assesses the potential costs of vapor monitoring and recordkeeping

for six and twelve months.

U NIVERSE OF 

### P OTENTIALLY 

### A FFECTED 

### UST S



### A total of 629,866 USTs were active according to EPA information sources. The most recent

data on the number of active USTs were obtained from the U.S. EPA, FY 2007 End of Year Activity Report

, memorandum from Cliff Rothenstein, Di rector Office of Underground Storage Tanks, to UST/LUST Regional Directors, Region s 1-10, December 5, 2007. The middle column of Table 1 presents the number of active USTs by state, territory, a nd in Indian Country.2 

### Model Site

The total cost estimated for the potential regulation of UST spill buckets, turbine sumps (sometimes referred to as tank sumps) and dispen ser pans (sometimes referred to as sumps) is estimated using a model of a typical gasoline st ation. The model site is assumed to have 2.65 underground storage tanks per stat ion. These tanks would be a combination of tanks holding high-grade gasoline, medium-grade gasoline, and low-grade gasoline. 1 

### Truck stops may have many more tanks and “ma and pa” gaso line stations may have fewer tanks.

The number of sumps for each UST can vary based on the type of tank that was installed and the type of product dispensed. For example, if th e tank is double-walled, ther e will be a separate sump for the interstitial sensor for the interstitial space and if th e tank contains gasoline and is in a State that requires stage I vapor recovery, there may be a sepa rate port for the state I vapor recovery poppet valve. In some cases, there isn’t a separate sump for the stage I vapor recovery because the tank has “coaxial” stage I vapor r ecovery which means the vapor is recovered through the fill pipe rather than a separate port. The automatic tank gauging system sensor may be in the large piping sump or it ma y be in its own separate sump.

All USTs will have at least the following:

1. Fill port sump with catch basin or “spill bucket.”

2. Piping sump (a.k.a. tank top sump or turbine su mp): these sumps ar e typically contained but not always.

Some USTs might also have the following sumps:

1. A separate sump for the automatic tank gauging system (if it is not in the piping sump). These sumps may or may not be contained.

2. A stage I recovery port sump (for gasoline ta nks and only in states where stage I vapor recovery is required. These may or may not be contained.

3. Tank interstitial sensor sumps. Only for ta nks that are double-walled. These may or may

not be contained.

4. Miscellaneous – some sites may have miscellaneous tank top openings (sumps) with components that have been capped off and are no longer used or are just “extra” openings for potential future use.

It is assumed that only those sumps that may c ontain gasoline/fuel will incur costs associated with tightness testing and vapor monitoring under the potential revisions to UST regulations. Those sumps include spill buckets and turbine sumps. The model site is assumed to have 2.65 spill buckets (one per tank fill pipe). A few large sites may have a manifold system for filling tanks and fewer fill pipes than the model site, but, this is not common. The model site also is assumed to have 2.65 turbine sumps (one per tank ) for the piping system associated with the

tanks.

2 U.S. EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, "Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures, October 24, 2007, Table 4.3 

### The number of dispensers at a site can vary grea tly as well. Many dispensers are contained using dispenser pans; however, some may not have a pan/sump. In the past, dispenser pans have not been a design requirement; however, this is becoming a more common requirement when installing/upgrading a dispenser. The model site is assumed to have 5.30 dispenser pans (two dispenser pans per ta nk) per model site. 2



### Table 1 presents the estimated number of model UST sites, spill buckets, turbine sumps, and dispenser pans by state, territor y, and in Indian Country. The estimated nationwide number of model UST sites is 237,685.

Baseline Conditions

Table 2 identifies states, territories and Tribal Nations that require tightness testing for spill buckets, sumps, and pans under current state (bas eline) regulations. Fi ve states have been identified as requiring tightness testing every year or every three years for spill buckets. Four

states have been identified as requiring tightness testing every th ree or five years for turbine sumps. Three states have been identified as re quiring tightness testing ev ery three or five years for dispenser pans. Upon further analysis, other states and territories may be determined to require tightness testing under curr ent state regulations. If such states are identified, baseline cost estimates will be higher and increm ental cost estimates will be lower.

Contacts from a national tightness testing contra ctor, Tanknology, stated th at approximately 4% of their clients conduct sump testing in stat es where they are not currently required to. 3 

### The primary driver of this is that th ese clients have a majority of thei r sites within states that require sump testing, so they conduct sump testing at all of their sites throughout the U.S. DPRA’s opinion is that clients of na tional tightness testing companies like Crompco and Tanknology may have less risk tolerance than the average UST ope rator, so the actual perc entage of sumps that fail is likely larger than presented and the percen tage of tank owners condu cting testing in states where it is not required may be le ss than 4%, and is probably closer to 2%. It is assumed they are conducting these tests on an annual basis as pa rt of their corporate best management practice

program.

P OTENTIAL 

### N EW 

### F EDERAL 

### UST R EGULATORY 

### R EQUIREMENTS



### Potential new federal UST regulatory requirement s include periodic tightness testing for UST spill buckets, sumps and pans, leak detection (i.e ., vapor monitoring), and recordkeeping. This memorandum presents cost impacts associated with reading the new regulations, conducting tightness testing on spill buckets, turbine sumps, a nd dispenser pans, the cost to repair spill buckets, sumps and pans that fail tightness test s, installation and operatio n of a vapor monitoring system, and recordkeeping for tight ness testing and vapor monitoring.

2 United States District Court for th e Western District of Wisconsin, United States of America v. Franklin Electric Co., Inc., United Dominion Industries Limited, and United Dominion Industries, Inc. , Filed May 31, 2000.

3 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA.4 

### U NIT 

### C OST 

### E STIMATES



### In order to assess the cost impacts associ ated with the potentia l new UST regulatory requirements, unit cost estimates were develope d for reading the regula tions, tightness testing, vapor monitoring and recordkeeping. Unit costs were developed based on previously published EPA documents, U.S. Department of Labor statistics, and vendor quotes.

Reading the Regulations

Newly regulated sites will need to read the re gulations on general operating requirements for conducting tightness testing and re lease detection for conducting vapor monitoring. The U.S.
EPA, Supporting Statement for EPA Informa tion Collection Request Number 1360.08, "Underground Storage Tanks: Technical and Fi nancial Requirements, and State Program Approval Procedures , (ICR 1360.08) October 24, 2007, provide s burden estimates for reading regulations on general operating requirements and release detection. Assuming tank tightness general operating labor burden requirements sp ecified in ICR 1360.08 are similar to spill bucket and sump general operating requirements, the la bor burden requirements for reading regulations on tightness testing general opera ting requirements include 0.25 hours of legal, 0.25 hours of managerial, and 0.5 hours of tec hnical labor. Assuming tank vapor monitoring release detection labor burden requirements specified in ICR 1360.08 are similar to sp ill bucket and sump release detection requirements, the labor burden re quirements for reading regulations on vapor monitoring release detection requ irements include 0.50 hours of legal, 0.50 hours of managerial,

and 1.0 hours of technical labor. Total labor burden requirements are estimated to include 0.75 hours of legal, 0.75 hours of manageri al, and 1.5 hours of technical labor. 4 

### Using the labor rate estimates described below, the average one-tim e cost per site to read and understand the regulations is $194.25 (0.75 hours x $95/hour + 0.75 hours x $60/hour + 1.5 x $52/hour). From
Table 1, there are an estimated 237,685 sites. Th e total one-time cost for reading the new UST regulatory requirements is estimated at $46.2 m illion ($194.25/site x 237,685 sites). Of this amount, $15.4 million ($64.75/site x 237,685 sites) is the one-time cost for reading tightness testing general operating requirements and $30.8 million ($129.75/site x 237,685 sites) is for reading release detection requirements for a vapo r monitoring system. These costs would be incurred upon any change in key personnel at the site. They have not been annualized in this preliminary assessment.

Tightness Testing

One of the primary requirements under potentia l new regulatory requirements is to conduct tightness testing on the spill buckets and sumps on either a one-year or three-year frequency. This section presents estimated costs for tightness testing of spill bucket sumps, tank turbine sumps, and dispenser pans, along wi th approximate repair costs if these tightness tests fail. We

4 For this preliminary analysis we did not estimate the labor costs for States to submit documents to EPA or administer the additional regulatory requirements. In additi on, labor costs for contractors to read and understand the regulations are assumed to be included in their overhead rates and incorporated into the unit cost estimates obtained from vendors for conducting tightness tests and vapor monitoring.5 

### will also discuss the percentage of tests that fail and the percentage of tank owners that are already conducting these tests in states where they are not requi red to do so. Todd Ferguson and Mark Lindsey of Tanknology, a national tightness tes ting firm, were the primary source of the cost estimates. Ed Kubinsky of Crompco’s presentation regarding Secondary Containment Testing at the 20 th 

### Annual Storage Tanks Conference in March 2008 was the primary source of pass/fail percentages. Mr. Lindsey of Tanknology also discussed pass/fail percentages, including comparisons between typical re gulated and non-regulated sites. 5



### Repair costs are included in the cost estimat e because we believe that UST operators are conducting a different type of maintenance unde r baseline compared to the new regulatory requirements being considered. Typically, states re quire that spill buckets must be kept clean of water and debris such that the buckets’ full cap acity is maintained and available to catch overfills. In addition, turbine sumps and dispense r pans must remain free of water, regulated substance and debris. Maintenance operations ty pically involve the removal of water, regulated substances, and debris and may involve conducting simple tighteni ng of pipe connections, etc.

under baseline. These "baseline" maintenance cost s are not what we are pricing in our repair

cost estimates. These same costs would be incurred under the potential new regulatory requirements; therefore, incremental costs are ze ro. Repair cost esti mates cover a range of activities from replacement of gaskets at the lo w end to installation of new buckets/sumps/pans at the high end.

Spill Bucket Sumps

Spill bucket sumps are located around points where the delivery driver connects hoses to the UST. While the costs for spil l bucket testing may slightly va ry depending upon the number of buckets at a site, the average cost to conduct tightness testing on spill buckets by vacuum is $125 per spill bucket. 6



### At sites in states where testing is require d, approximately 13.5% of spill bucket tightness tests

fail. 7 

### Repair costs may range from $200 to $2,000, depending upon the severity of the failure. The typical repair cost is $400. 8



### At sites in states where testing is not required or at a site that ha s not been tested before, at least 30% of spill bucket tests fail. 9 

### The estimated average test failu re percentage over the 20-year life of a gasoline service station is 15.6%. 10, 11 

### The typical repair cost for failures at these sites is

5 Mr. Lindsey has never had to conduct sump testing in a cold-weather environment. He said that all of our pass/fail percentages seem very appropriate for warm-weather states, but he is fairly certain that the failure percentages would be higher if testing was required in the cold-w eather states, due to freeze/th aw cycles, upheaving, snowplowing, and other related issues. Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with
Donovan Hannu, DPRA.

6 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA.

7 Kubinsky, Edward, Jr., Special Projects Manager, Crompco, LLC, Secondary Containment Testing , 20th Annual National Storage Tanks Conference, Atlanta, GA, March 17, 2008.

8 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

9 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

10 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - http://www.irs.gov/publications/p946/13081f40.html).6 

### $1,000. 12 

### Using a similar approach to the estimated average test failure pe rcentage, the typical repair cost over the 20-year life of a gasoline service station is $475. 13



### Turbine Sumps

Turbine sumps may house the submersible turbine pump head, piping, leak detectors, wiring, and other equipment. While the costs for turbin e testing may slightly vary depending upon the number of sumps at a site, the average cost to conduct tightness tes ting on turbine sumps by vacuum is $150 per sump. 14



### At sites in states where testing is required, approximately 22% of turbine sump tightness tests

fail. 15 

### Repair costs may range from $200 to $3,000, depending upon the severity of the failure. The typical cost of repa irs at these sites is $600. 16



### At sites in states where testing is not required or at a site th at has not been tested before, approximately 45% of turbine sump tests fail. 17 

### The estimated average test failure percentage over the 20-year life of a gasoline service station is 24.9%. 18,19 

### The typical repair cost for

failures at thes e sites is $1,200. 20 

### Using a similar approach to the estimated average test failure percentage, the typical repair cost over the 20- year life of a gasoline service station is $675. 21

11 The 30% spill bucket test failure rate is an approximation for when state tightness testing programs are initially created. After the first few years (and tightness tests) all pa rts that might fail or are weakened at the initiation of the state tightness testing program will be replaced. A fully established state program is estimated to have 13.5% of the tests fail. For cost estimation purposes, we assume that ov er a five year period the test failure rate will steadily decline from 30% to 13.5% and the test failure rate will remain constant at 13.5% for years 5 through 20.

12 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

13 The $1,000 spill bucket repair cost is an approximation for when state tightness testing programs are initially created. After the first few years (and tightness tests) all pa rts that might fail or are weakened at the initiation of the state tightness testing program will be replaced. A fully established state program is estimated to have $400 for a typical spill bucket repair cost. For cost estimation purposes , we assume that over a five year period the spill bucket repair cost will steadily decline from $1,000 to $400 and th e typical repair cost will remain constant at $400 for years 5 through 20.

14 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA.

15 Ferguson, Todd and Mark Lindsey, Tanknology June 2008. Personal Communication with Donovan Hannu,

DPRA.

16 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

17 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

18 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - http://www.irs.gov/publications/p946/13081f40.html).

19 The 45% turbine sump test failure rate is an approximati on for when state tightness testing programs are initially created. After the first few years (and tightness tests) all pa rts that might fail or are weakened at the initiation of the state tightness testing program will be replaced. A fully established state program is estimated to have 22% of the tests fail. For cost estimation purposes, we assume that ov er a five year period the test failure rate will steadily decline from 45% to 22% and the test failure rate will remain constant at 22% for years 5 through 20.

20 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

21 The $1,200 turbine sump repair cost is an approximati on for when state tightness testing programs are initially created. After the first few years (and tightness tests) all pa rts that might fail or are weakened at the initiation of the state tightness testing program will be replaced. A fully established state program is estimated to have $600 for a typical turbine sump repair cost. For cost estimation purpos es, we assume that over a five year period the turbine sump repair cost will steadily decline from $1,200 to $600 and the typical repair cost will remain constant at $600 for years 5 through 20.7 

### Dispenser Pans

Dispenser pans provide access to piping, flex co nnectors, shear valves, and other equipment directly beneath each dispense r. The average cost to condu ct dispenser pan testing using hydrostatic methods is $180 per sump. 22 

### This cost does not include testing water disposal, due to wide range of disposal options for each state.

At sites in states where testi ng is required, approximately 18.5% of dispenser pan tightness tests

fail. 23 

### Repair costs may range from $200 to $2,000, 24 

### depending upon the severity of the failure.

The most common failure involves su mps that are not water-tight. Th e typical cost of repairs at these sites is $400. 25



### At sites in states where testing is not required or at a site that ha s not been tested before, at least 40% of dispenser pan tests fail. 26 

### The estimated average test failure percentage over the 20-year life of a gasoline service station is 21.2%. 27,28 

### The typical repair cost for failures at these sites is $800. 29 

### Using a similar approach to the estimated average test failure percentage, the typical repair cost over the 20-year life of a gasoline service station is $450. 30



### Vapor Monitoring Leak Detection Systems

Another requirement under potential new regulator y requirements for USTs is to conduct vapor monitoring. This section presents estimated cost s associated with using either continuous or periodic vapor monitoring as leak detection me thods. For a fully continuous vapor monitoring system we assumed it involves using vapor mon itoring points near each spill bucket, turbine sump and dispenser pan, installing vapor sensors in each point, connecting the sensors to an automatic tank gauging (ATG) system, and upgradi ng the ATG system to handle the additional vapor sensors. This system represents the hi ghest cost leak detecti on method. For a periodic vapor monitoring system a vapor monitoring point is installed near each spill bucket, turbine

22 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA.

23 Lindsey, Mark Lindsey, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

24 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA.

25 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA.

26 Lindsey, Mark, Tanknology, June 2008, 2008. Personal Communication with Donovan Hannu, DPRA.

27 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - http://www.irs.gov/publications/p946/13081f40.html).

28 The 40% dispenser pan test failure rate is an approxima tion for when state tightness testing programs are initially created. After the first few years (and tightness tests) all pa rts that might fail or are weakened at the initiation of the state tightness testing program will be replaced. A fully established state program is estimated to have 18.5% of the tests fail. For cost estimation purposes, we assume that ov er a five year period the test failure rate will steadily decline from 40% to 18.5% and the test failure rate will remain constant at 18.5% for years 5 through 20.

29 Lindsey, Mark Lindsey, Tanknology, July 2, 2008, 2008. Personal Communication with Donovan Hannu, DPRA.

30 The $800 dispenser pan sump repair cost is an approximation for when state tightness testing programs are initially created. After the first few years (and tightness te sts) all parts that might fail or are weakened at the initiation of the state tightness testing program will be repl aced. A fully established stat e program is estimated to have $400 for a typical dispenser pan repair cost. For cost estimation purposes, we assume that over a five year period the dispenser pan repair cost will steadily decline from $800 to $400 and the typi cal repair cost will remain constant at $400 for years 5 through 20.8 

### sump and dispenser pan and a soil gas sample is collected and analyzed ei ther on a six month or annual basis. Attachment A presents an estimate of soil sampling costs that could be incurred to determine if a leak occurred resulting from a failed tightness test. This one-time investigative

leak detection method invol ves collecting and analyz ing a soil sample for the regulated substance near the bucket/sump/pan.

It should be noted that both continuous and periodic vapor monitoring systems (and soil sampling) can have a high frequency of false positives from previous petroleum releases at the site. Numerous sites have had previous petroleu m releases that have not been cleaned to more stringent cleanup standards. For example, they could have been clean ed to industrial or commercial cleanup standards that allow higher c oncentrations of petroleum contaminants to

remain on the site rather than a residential cleanu p standard that requires lower concentrations.

Even contamination that remains at sites cleane d to residential standards could trigger a false positive “leak” detection result depending on the sensitivity of the equipment used and location of previous petroleum releases.

Continuous Vapor Monito ring Leak Detection

Information for this analysis was obtained from Scott Olson at Northland Petroleum Service.

Mr. Olson serviced several leak detection systems using vapo r monitoring approximately 15 years ago, before his clients quit using the method due to problems associated with it. Mr. Olson states that vapor monitoring is nearly worthl ess as a leak detection method due to several problems inherent with the method. These problems are associated with false positives, inability to confirm sensor readings, a nd previous petr oleum releases.

Many of the UST system components and material s can falsely trigger a vapor sensor. These materials include resins used in fiberglass tanks , gortex membranes, and chemical solvents used

to wash USTs before installation and/or coati ng. In addition, many UST sites are located on property where a petroleum release has previously occurred, so contamin ation associated with the previous release may trigge r the vapor sensors, especially during fluctuating groundwater conditions. The biggest problem associated with using vapor m onitoring as a leak detection method is the inability to confirm the existence of vapors in the sensor point. After a vapor sensor alarm goes off, any vapors that may have caused the alarm immediately dissipate as soon as the vapor monitoring point lid is opened. There is no way of documenting whether the vapor sensor actually detected vapors or if it was a false positive.

In addition, Mr. Olson stated that because of the hazards associated with drilling above and directly adjacent to existing pipi ng and tanks, vapor monitoring point s will have to be installed by hand at each site.

Mr. Olson provided the following uni t costs associated with retro- fitting a typical UST system to use vapor monitoring as a leak detection method.

• Install vapor monitoring points by hand near each sump: $5,000

• Vapor sensors (10.6 sensors @ $500/sensor): $5,3009 

### • Install new cards in ATG system to handle vapor sensors (three cards @ $500/card): $1,500

• Install new dedicated conduits and wiring from sumps to ATG: $7,000

The total cost for retro-fitting a typical UST sy stem that already has an ATG system is $18,800. Converting this one-time retro-fit cost into an annual cost, assu ming a 7 percent discount rate over the 20-year life of the gasoline servic e station, results in an annual cost of $1,775. 31 

### Not all UST systems have ATG systems. Sixty-six percen t of the sites are assumed to already have an ATG system. 32 

### Other sites that use other leak detec tion methods such as annual tightness testing and statistical inventory reconciliation (SIR) w ould require substantial additional costs for an ATG system. These costs may average appr oximately $20,000. Converting this one-time

installation cost into an annual cost, assuming a 7 percent disc ount rate over the 20-year life of the gasoline service st ation, results in an annual cost of $1,888. 33 

### In contrast, 34 percent of the

sites are assumed to not have an ATG system incurring both th e retrofit cost ($1,775 per year) and ATG system cost ($1,888 per year).

Operation and maintenance of vapor monitoring systems in clude calibration, cleaning and replacement of defective sensors. Calibration and cleaning is estimated to cost $250 per year. 34 

### Sensors cost $500 each. They are known to fail frequently. 35 

### One-sixth of the 10.6 sensors are assumed to be replaced annually based on best pr ofessional judgment for a total cost of $883 per year. Total vapor monitoring operation and main tenance costs are estimated to be $1,133 per

year.

Periodic Vapor Monitoring Leak Detection Method

Another leak detection method is to periodic vapor monitoring. Advancing vapor monitoring points by hand and collecting soil-gas samples would determine if a release impacted the subsurface at UST sites. The following unit co sts were assumed to retro-fit a typical UST system to use vapor monitoring as a leak detection method:

• Install vapor monitoring points by hand near each sump (10.6 vapor monitoring points per site): $5,000

• Collect soil gas sample from each vapor monitoring point per sampling event: $300 36

31 Capital recovery factor (i.e., the am ount of each future annuity payment requ ired to accumulate a given present value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $18,800 x 0.09439 = $1,775.

32 U.S. EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, "Underground Storage Tanks: Technical and Financial Requirements, an d State Program Approval Procedures, October 24, 2007,

Table 4.

33 Capital recovery factor (i.e., the am ount of each future annuity payment requ ired to accumulate a given present value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $19,500 x 0.09439 = $1,888.

34 Pyles, Charles, Precision Testing, White Plains, Maryland, July 3, 2008. Personal communications with Mary Blel, DPRA.

35 Pyles, Charles, Precision Testing, White Plains, Maryland, July 3, 2008. Personal communications with Mary Blel, DPRA.

36 DPRA best professional judgment.10 

### • Soil gas laboratory analysis per sample: $90 37



### The one-time vapor monitoring point installation cost of $5,000 converted into an annual cost, assuming a 7 percent discount rate over the 20-year li fe of the gasoline service station, results in an annual cost of $472. 38 

### On a per vapor monitoring point basis the annual cost is $45 ($472/10.6 points = $45). Soil gas sampling is es timated to be $300 per sampling event for the entire site. On a per vapor monitoring point basis the soil gas sampling unit cost is $28 per sampling event ($300/10.6 points = $28). So il gas laboratory analysis costs are $954 per sampling event for the entire site ($90 *10.6 poi nts = $954). On a per vapor monitoring point basis the soil gas laboratory analysis unit co st is $90 per sample. Total periodic vapor monitoring costs are estimated to be $1,726 per y ear per site if annual soil gas sampling is conducted or $2,980 per year per site if se mi-annual soil gas sampling is conducted.

Recordkeeping

Newly regulated sites will need to keep records for tightness testing and vapor monitoring. The
U.S. EPA, Supporting Statement for EPA Informa tion Collection Request Number 1360.08, "Underground Storage Tanks: Technical and Fi nancial Requirements, and State Program Approval Procedures , (ICR 1360.08) October 24, 2007, provides burden estimates for maintaining records for tightness tests under ge neral operating requirements and monthly tank vapor monitoring results for release detection requirements – scenarios examine recordkeeping annually or twice annually (every six months). Assuming tank tightness general operating labor burden requirements specified in ICR 1360.08 are similar to spill bucket and sump general operating requirements, the labor burden requirements for maintain ing records of tightness tests include 0.10 hours of clerical pe r test plus $0.10 for materials pe r test. Using the labor rate estimates described below, the average cost fo r maintaining tightness testing records is $3 per test (0.1 hours x $26/hour).

Assuming tank vapor monitoring release detectio n labor burden requirements specified in ICR 1360.08 are similar to spill bucket and sump rel ease detection requirements, the labor burden requirements for maintaining records of vapor monitoring results include 1.67 hours of technical labor for 12 monthly recordings. A per record ing event estimate of 0.14 hours is derived by dividing the labor burden hours by 12 . In addition, capital/startup costs are estimated to be $733 per site. Converting this one-t ime annual/startup cost into an annual cost, assuming a 7 percent discount rate over the 20-year life of the gasoline service station, results in an annual cost of
$69. 39 

### Using the labor rate estimates described below, the average cost to maintain vapor monitoring records is $15 pe r recordkeeping recording ev ent (0.14 hours x $52/hour).

37 DPRA best professional judgment.

38 Capital recovery factor (i.e., the am ount of each future annuity payment requ ired to accumulate a given present value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $5,000 x 0.09439 = $472.

39 Capital recovery factor (i.e., the am ount of each future annuity payment requ ired to accumulate a given present value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $733 x 0.09439 = $69.11 

### Labor Costs

The table below shows the estimated average hourl y labor cost (including overhead and fringe), by labor category. These labor ra tes are used to calculate the labor cost for reading the regulations and conducting the reporti ng and recordkeeping activities.

Average Hourly Labor Cost by Labor Category (2007 dollars) Legal Managerial Technical Clerical Sites $95 $60 $52 $26

To obtain hourly labor costs (other than legal labor costs) for sites, the private industry employer costs (including fringe benefits for paid leave, supplemental pay, insurance, retirement and savings, and legally required benefits for manage ment workers) provided by the Bureau of Labor Statistics (BLS) in May 2008 were used. 40 

### To obtain hourly legal labor costs, BLS national occupational employment and wage estimates fo r May 2007 (plus an additional 44 percent of the base for fringe benefits) were used and then adjusted for 200 8 dollars using the 3.2 percent 2008 Employment Cost Index. 41, 42 

### Additional administrative expe nses of a business that are necessary for a business to functi on is referred to as overhead. Typical overhead costs include rent, utilities and property insura nce. The overhead rate is estimated as 12 percent of the base and fringe benefit labor rate. 43

40 U.S. Department of Labor. Bureau of Labor Statistics (BLS). Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Private industry workers, by occupational group and full-time and part-time status (M arch 2008); available from < http://www.bls.gov/news .release/ecec.t11.htm >; accessed July 2, 2008. Total co mpensation (including fringe for paid leave, supplemental pay, insurance, retirement and savings, and legally required benefits) for management workers is $53.93/hour, professional workers is $46.36 per hour, and Office workers is $23.11 per hour. Wages and salaries alone are $37.46 per hour, $32.91 per hour, and $15.97 per hour, respectively.

41 U.S. Department of Labor, Bureau of Labor Statistics (BLS). Occupational employment and wages – 23-1011 Lawyers [see “National estimates for this occupation” , “mean hourly wage”] (May 2007); available from

< http://www.bls.gov/oes/current/oes_nat.htm >; accessed July 2, 2007. The mean hourly wage was $56.87 in 2007 (excluding fringe). Assumed a fringe rate equivalent to the rate received by management workers noted previously ($53.93/hour/$37.46/hour = 1.44 => 44% fringe rate).

42 The Employment Cost Index (ECI) is 3.2 percent (wages and salaries for private industry) from March 2007 to March 2008. BLS. News release: Employment Cost Index (March 2008) [see Table B]; available from < http://www.bls.gov/news.release/eci.nr0.htm >.

43 OMB Circular No. A-76 - Table C, May 29, 2003, Summary of Standard Competition Form (SCF) line 4, http://www.whitehouse.gov/omb/circulars /a076/a76_incl_tech_correction.pdf12 

### S UMMARY OF 

### C OST 

### I MPACTS



### Cost impacts associated with th e potential new UST regulations are estimated to range from $0.2 billion per year if pot ential regulatory re quirements only include tightness testing being conducted every three years and no vapor monitoring leak detection to $1.5 billion per year if potential regulatory requirements include annual tightness testing and continuous vapor monitoring leak detectio n with semi-annual recordkeeping. The table below presents a summary

of the total incremental annual cost estimate for reading the regulat ions, tightness testing conducted either annually or every three years, repair, leak detection us ing either periodic or continuous vapor monitoring system and recor dkeeping including continuous vapor monitoring recordkeeping every six or twelve months. These estimates incorporate no existing state regulations into the baseline rega rding leak detection. If states currently require leak detection,

the incremental cost estimates are overstated.

Reading the regulation costs are estimated to ra nge between $15 and $46 million in the first year for tightness testing requiremen ts or both vapor monitoring leak detection and tightness testing requirements, respectively. If other leak detection methods ar e chosen costs for reading the regulations would fall within this range. Co sts were not annualized in this preliminary assessment to account for any changes in key personnel in subsequent years.

Tightness testing costs are estimated to ra nge from $117 to $365 million per year depending whether tightness testing is conducted every thre e years or annually. Concurrently, spill bucket, turbine sump and dispenser sump repair costs are estimated to range from $64 to $231 million per year. Recordkeeping costs associated with tig htness testing are estimated to range from $4 to $6 million per year. 44



### Two types of leak detection methods are incor porated into the cost estimates, periodic and continuous vapor monitoring systems. If the inst allation of a periodic vapor monitoring system is an acceptable method (even with all its associ ated false positive problems) to determine if a

leak/release occurred from a buc ket/sump/pan the costs are estimated to range from $409 to $708 million per year depending whether recordkeepi ng is required every twelve months or six

months. If the installation of a cont inuous vapor monitoring system at all UST facilities is an acceptable method (even with all its associated false positive and equipment problems) to

determine if a leak/release occurred from a bucke t/sump/pan the costs are estimated to cost $844 million annually and recordkeeping is estimated to range from $20 to $26 million per year depending whether recordkeeping is require d every twelve months or six months.

44 Other options for tightness testing include varying the test ing frequency. Currently, some states test spill buckets every one to three years, turbine sumps every three to five years, and dispense r pans every three to five years. Another option not presented in the table that would lower costs would be to conduct tightness testing annually for spill buckets and every five years for turbine sumps and dispenser pans. Tightness testing costs are estimated to be $68 million per year and repair costs are estimated to be $63 million per year.13 Total Estimated Incremental Annual Costs

(million dollars, 2008)

Tightness Testing (annual) Tigh tness Testing (every 3 years)

Vapor

Monitoring

Recordkeeping

every 6 months Vapor

Monitoring

Recordkeeping

every 12 months Vapor

Monitoring

Recordkeeping

every 6 months Vapor

Monitoring

Recordkeeping

12 months 

### Reading the regulations (First-year Cost)

- Tightness Testing Only $15 $15 $15 $15

- Vapor Monitoring &

Tightness Testing $46 $46 $46 $46



### Tightness Testing

Spill Buckets

Turbine Sumps

Dispenser Pans

Total $68

$87

$210

$365 $68

$87

$210

$365 $21

$28

$68

$117 $21

$28

$68

$117 

### Spill Bucket/Turbine Sump/Dispenser Pan Repair

Spill Buckets

Turbine Sumps

Dispenser Pans

Total $40

$89

$101

$231 $40

$89

$101

$231 $13

$24

$27

$64 $13

$24

$27

$64 

### Vapor Monitoring Leak Detection

- Periodic Vapor Monitoring

Spill Buckets

Turbine Sumps

Dispenser Pans

Total

- Continuous Vapor Monitoring

of all buckets, sumps and pans $177

$177

$354

$708

$844 $102

$102

$205

$409

$844 $177

$177

$354

$708

$844 $102

$102

$205

$409

$844 

### Recordkeeping

- Tightness Testing Only $6 $6 $4 $4

- Vapor Monitoring &

Tightness Testing $26 $25 $22 $20



### First-Year Total

- Tightness Testing Only $617 $617 $200 $200

- Vapor Monitoring &

Tightness Testing $1,376 - $1,512 $1,076 - $1,511 $957 - $1,093 $656 - $1,091



### Subsequent-Year Total

- Tightness Testing Only $602 $602 $185 $185

- Vapor Monitoring &

Tightness Testing $1,330 - $1,466 $1,030 - $1,465 $911 - $1,047 $610 - $1,04514Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser PansState/Territory/Indian CountyNumber of ActiveUSTsNumber of Model USTSitesNumber of Model SpillBucketsNumber of ModelTurbine SumpsNumber of ModelDispenser PansAK 1,151 434 1,151 1,151 2,302AL 18,885 7,126 18,885 18,885 37,770AR 9,455 3,568 9,455 9,455 18,910AS 16 6 16 16 32AZ 7,003 2,643 7,003 7,003 14,006CA 37,498 14,150 37,498 37,498 74,996CNMI 68 26 68 68 136CO 7,949 3,000 7,949 7,949 15,898CT 10,849 4,094 10,849 10,849 21,698DC 696 263 696 696 1,392DE 1,467 554 1,467 1,467 2,934FL 28,862 10,891 28,862 28,862 57,724GA 30,049 11,339 30,049 30,049 60,098GU 267 101 267 267 534HI 1,692 638 1,692 1,692 3,384IA 7,372 2,782 7,372 7,372 14,744ID 3,302 1,246 3,302 3,302 6,604IL 22,574 8,518 22,574 22,574 45,148IN 13,840 5,223 13,840 13,840 27,680KS 6,967 2,629 6,967 6,967 13,934KY 12,415 4,685 12,415 12,415 24,830LA 12,601 4,755 12,601 12,601 25,202MA 11,021 4,159 11,021 11,021 22,042MD 9,243 3,487 9,243 9,243 18,486ME 3,199 1,207 3,199 3,199 6,398MI 20,155 7,606 20,155 20,155 40,310MN 14,532 5,484 14,532 14,532 29,064MO 10,267 3,874 10,267 10,267 20,53415Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser PansState/Territory/Indian CountyNumber of ActiveUSTsNumber of Model USTSitesNumber of Model SpillBucketsNumber of ModelTurbine SumpsNumber of ModelDispenser PansMS 8,782 3,314 8,782 8,782 17,564MT 3,290 1,242 3,290 3,290 6,580NC 28,705 10,832 28,705 28,705 57,410ND 2,163 816 2,163 2,163 4,326NE 6,903 2,605 6,903 6,903 13,806NH 3,063 1,156 3,063 3,063 6,126NJ 16,830 6,351 16,830 16,830 33,660NM 4,027 1,520 4,027 4,027 8,054NV 3,669 1,385 3,669 3,669 7,338NY 28,897 10,905 28,897 28,897 57,794OH 22,998 8,678 22,998 22,998 45,996OK 11,102 4,189 11,102 11,102 22,204OR 6,112 2,306 6,112 6,112 12,224PA 24,677 9,312 24,677 24,677 49,354PR 4,560 1,721 4,560 4,560 9,120RI 1,627 614 1,627 1,627 3,254SC 11,981 4,521 11,981 11,981 23,962SD 3,021 1,140 3,021 3,021 6,042TN 17,105 6,455 17,105 17,105 34,210TX 54,946 20,734 54,946 54,946 109,892UT 4,024 1,518 4,024 4,024 8,048VA 20,600 7,774 20,600 20,600 41,200VI 144 54 144 144 288VT 3,067 1,157 3,067 3,067 6,134WA 10,112 3,816 10,112 10,112 20,224WI 13,725 5,179 13,725 13,725 27,450WV 5,696 2,149 5,696 5,696 11,392WY 1,980 747 1,980 1,980 3,960IndianCountry2,665 1,006 2,665 2,665 5,33016Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser PansState/Territory/Indian CountyNumber of ActiveUSTsNumber of Model USTSitesNumber of Model SpillBucketsNumber of ModelTurbine SumpsNumber of ModelDispenser PansTOTAL 629,866 237,685 629,866 629,866 1,259,73217Table 2. Current (Baseline) State Tightness Testing Regulatory RequirementsSpill Buckets Tank Sumps Dispenser PansState/Territory/Indian CountyNumber ofActive USTsNumber ofModel USTSitesTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyAK 1,151 434 N N NAL4518,885 7,126 Y Annual N NAR 9,455 3,568 N N NAS 16 6 N N NAZ 7,003 2,643 N N NCA4637,498 14,150 Y Annual N NCNMI 68 26 N N NCO 7,949 3,000 N N NCT 10,849 4,094 N N NDC 696 263 N N NDE471,467 554 Y Annual Y 3 years Y 3 yearsFL 28,862 10,891 N N NGA 30,049 11,339 N N NGU 267 101 N N NHI 1,692 638 N N NIA 7,372 2,782 N N NID 3,302 1,246 N N NIL 22,574 8,518 N N NIN 13,840 5,223 N N NKS 6,967 2,629 N N N45Alabama Department of Environmental Management, Water DivisionWater Quality Program, Administrative Code, Chapter 335-6-15, Technical Standards,Corrective Action Requirements and Financial Responsibilityfor Owners and Operators Of Underground Storage Tanks,http://www.alabamaadministrativecode.state.al.us/docs/adem/McWord335-6-15.pdf46California Fire Code, California Health and Safety Code, Chap 6.7, Section 25284.247http://www.dnrec.state.de.us/dnrec2000/Divisions/AWM/ust/pdf/2008%20UST%20Regulations.pdf18Table 2. Current (Baseline) State Tightness Testing Regulatory RequirementsSpill Buckets Tank Sumps Dispenser PansState/Territory/Indian CountyNumber ofActive USTsNumber ofModel USTSitesTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyKY 12,415 4,685 N N NLA 12,601 4,755 N N NMA4811,021 4,159 N Y 3 years NMD499,243 3,487 Y Annual Y 5 years Y 5 yearsME 3,199 1,207 N N NMI 20,155 7,606 N N NMN 14,532 5,484 N N NMO 10,267 3,874 N N NMS 8,782 3,314 N N NMT 3,290 1,242 N N NNC 28,705 10,832 N N NND 2,163 816 N N NNE 6,903 2,605 N N NNH 3,063 1,156 N N NNJ 16,830 6,351 N N NNM 4,027 1,520 N N NNV 3,669 1,385 N N NNY 28,897 10,905 N N NOH5022,998 8,678 Y 3 years Y 3 years Y 3 yearsOK 11,102 4,189 N N N48Massachusetts 527 CMR: Board of Fire Prevention Regulations,http://www.mass.gov/Eeops/docs/dfs/osfm/cmr/cmr_secured/527009.pdf49Maryland Department Of The Environment, Oil Control Program, Underground Storage Tank (UST) Systems Compliance Outline, May 7,2008,http://www.dsd.state.md.us/comar/subtitle_chapters/26_Chapters.htm50Ohio, 1301:7-9-01 Applicability,http://www.com.state.oh.us/sfm/pub/bust_1301_7-9.pdf19Table 2. Current (Baseline) State Tightness Testing Regulatory RequirementsSpill Buckets Tank Sumps Dispenser PansState/Territory/Indian CountyNumber ofActive USTsNumber ofModel USTSitesTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyTightnessTestingReq’d.(Y/N)TightnessTestingFrequencyOR 6,112 2,306 N N NPA 24,677 9,312 N N NPR 4,560 1,721 N N NRI 1,627 614 N N NSC 11,981 4,521 N N NSD 3,021 1,140 N N NTN 17,105 6,455 N N NTX 54,946 20,734 N N NUT 4,024 1,518 N N NVA 20,600 7,774 N N NVI 144 54 N N NVT 3,067 1,157 N N NWA 10,112 3,816 N N NWI 13,725 5,179 N N NWV 5,696 2,149 N N NWY 1,980 747 N N NIndianCountry2,665 1,006 N N NTOTAL 629,866 237,68520 

### ATTACHMENT A

Soil Sampling as a Leak Detection Method

Another “leak detection” method involves colle cting and analyzing a soil sample for the regulated substance near the bucket/sump/pan to determine if a release has impacted the subsurface. This cost estimate represents an activity that is only conducted at sites where the UST sumps, spill buckets, or dispenser pans fail their tightness testing. This trigger may be further refined to say that soil sampling is onl y conducted at sites faili ng their tightness testing

because of containment failure. Our full failure percentage estimates are used in developing the cost estimates presented in this memorandum. We assumed it will cost approximately $500 to collect a soil sample. In addition we assumed a laboratory analysis cost of $60 per sample for detection of petroleum products. 51

Total Estimated Soil Samplin g Incremental Annual Costs

(million dollars, 2008)

Tightness Testing

(annual) Tightness Testing

(every 3 years)

- Soil Sampling by

Spill Buckets

Turbine Sumps

Dispenser Pans

Total $54

$83

$142

$279 $21

$29

$49

$99

51 DPRA best professional judgment.DRAFT – DO NOT CITE OR QUOTE



### APPENDIX C

Assessment of Baseline and Cost Impacts Associated with De-Regulatory OptionsDRAFT – DO NOT CITE OR QUOTE

2 

### Preliminary Assessment of Baseline and Co st Impacts Associated with Deregulatory Options

Under Resource Conservation and Recovery Act ( RCRA) Subtitle I, EPA promulgated technical and financial requirements for owners and op erators of underground storage tanks (USTs). 1 

### EPA’s Office of Underground Stor age Tanks (OUST) is investig ating options for removing certain requirements; these revisions will reduce cost s and are not expected to result in decreased protection of human health and the environment. Under Task 4 of Work Assignment 1-25, IEc investigated the preliminary cost savings associated with three deregulato ry options, including:

• Reducing the length of recordkeeping time for repairs for the life of the UST systems to three, five, or 10 year time frames;

• Reducing the length of recordk eeping time for leak detecti on results to six consecutive months; and

• Removing the requirement for corrosion protec tion associated with safe suction steel piping.

This screening level assessment is based principally on the supporting statement for the EPA information collection request (ICR ) Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures , EPA ICR Number 1360.08. In addition, IEc examined summarized state re gulatory informati on available in the Underground Storage Tank Guide published by Thomson Publishing Comp any, previous contractor reports produced by E2 Environmental, Inc., and co nducted phone discussions with UST system

installers.

We discuss each of the deregulat ory options below. For the recordkeeping requirements, we include brief descriptions of the deregulatory options, methodologies, results, and limitations for each analysis. For corrosion protection for sa fe suction steel piping, we provide a brief discussion of our finding that co st savings from deregulation ar e unlikely to be significant.

Reducing Recordkeeping Time for Repairs

Section 280.33(f) requires owners and operators to maintain reco rds of each repair for the operating life of the UST system. These record s must demonstrate that repairs will prevent

releases due to structural failure or corrosion as long as the UST sy stem is used to store regulated

substances. 2 

### Under the investigated deregulatory options, we estimate the cost savings associated with reducing recordkeeping time for repairs from the lifetime of the UST system to three, five, or 10-year time frames.

1 40 CFR Part 280.

2 Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures

, EPA ICR Number 1360.08DRAFT – DO NOT CITE OR QUOTE

3 

### Methods, Assumptions, and Data Sources

ICR 1360.08 provides cost burden information on th e maintenance of records associated with UST system repairs. The ICR estimates a cost bu rden of $3.86 per repair for the life of the UST system; of which $3.76 is attribut ed to labor costs, and $0.10 is attributed to operation and maintenance. In addition, EPA estimates that three percent of USTs (out of 629,167) will be repaired each year, totaling 18,875 repairs, and one re pair per facility. Exhibit 1 summaries that key assumptions and data sources used to estim ate the cost savings associated with reducing recordkeeping time for UST repairs. 3

Exhibit 1

Key Assumptions and Data Sources Used to Esti mate Cost Savings Associated with Reduced Recordkeeping Time for UST Repairs.
Assumption Data Source Recordkeeping costs per repair $3.86 ICR 1360.08 Number of UST repairs per year 18,875 ICR 1360.08 Useful life of UST system (years) 20 ICR 1360.08

Discount rate 7% Office Management and Budget Circular A-94 (in ICR 1360.80) Total repair recordkeeping costs per year a $72,858 ICR 1360.08

Notes:

a Value does not match ICR due to rounding.



### The ICR does not clarify how it tr eats the yearly costs associat ed with recordkeeping for UST repairs. It is unclear whether the cost per repair ($3.86) is incu rred during the first year or over the lifetime of the UST system (20 years). B ecause the ICR identifies only 18,875 annual repairs requiring record maintenance, and does not explicitly estimate the cost of maintaining records from previous years’ repairs for other facilities, we assume that the estimated cost represents the entire cost to maintain repair records for the lifetime of the UST system each time a repair is necessary. In addition, to simplify the analysis for this preliminary estimate, we assume that all repairs occur in the first year of installation. 4



### In order to estimate cost savings associated wi th reducing recordkeeping time, we establish the

baseline costs of the current rule. Since recordk eeping regulations for repa irs require facilities to maintain records for the life of the UST system, operators incur costs in the years that follow repairs at discounted rates. Based on the assu mptions stated above, we first annuitize the cost per repair ($3.86) over the lifetime of an UST sy stem, resulting in payments of approximately

3 All costs reported in 2007 dollars.

4 Note that we do not include the potential cost of re ading the regulations in these preliminary estimates.DRAFT – DO NOT CITE OR QUOTE

4 

### $0.34 per year for 20 years. 5 

### We then discount these payments out for 20 years at the OMB approved 7 percent discount rate. 6



### To reflect that costs continue for the life of the UST system, we estimate the number of “recordkeeping events” in a given year to be the product of year s away from retirement of the UST systems multiplied times the number of repairs in a given year. For example, in year-one, we assume that operators will pay for recordkeeping on all repairs that occurred in the last 20 years, resulting in 337,5 00 recordkeeping events (18,875 x 20). In year-two, we assume that only those repairs occurring in th e last 19 years will result in r ecordkeeping events, as one cohort of repaired systems (i.e., the 20-year old UST systems) is retired.

We then multiply the number of recordkeeping events times previously estimated discounted payments. We then sum the yearly values to arrive a total present value of $924,102. Finally, we annualize this sum over 20-ye ar period at a discount rate of 7 percent, which results in annualized total cost of $87,229 per year. Exhib it 2 presents the calc ulations employed to

estimate the baseline.

5 Note that we calculate the annuity payments using MS Excel’s PMT function, which calculates the annuity payment based on constant payments and a constant interest rate.

6 For example, we estimate the present value cost in year-one to be approximately $0.34, present value cost in yeartwo to be approximately $0.32, and the present value cost in year three to be approximately $0.30. The sum of the present values calculations for each year total $3.86.DRAFT – DO NOT CITE OR QUOTE

5 

### To estimate the three deregulatory options presen t by EPA, we use the same procedure as above, and modify years examined and number of recordk eeping events to reflect each scenario. Under the three-year scenario, operators must maintain records for repairs occurring within the last three years. Therefore, using the three-year scenario, we estimate the number of recordkeeping events in year-one to be the number of annua l repairs multiplied by three (56,625); in year-two the number of recordkeeping events totals 37,350 (2 x 18,875); and in year-three, the number of recordkeeping events equals 18,875. Once agai n, for each year, we multiply the number of recordkeeping events by the discounted cost pa yment in that year. We then sum the yearly values to arrive a total pres ent value of $36,910. Finally, we annualize this sum over 20-year period at a discount rate of 7 percent, which results in annua lized total cost of $3,484 per year. Attachment A presents the calculations employed to estimate the three-year, five-year, and 10- year scenarios.

Results

In order to calculate the cost savings associat ed with each deregulatory option, we subtract the

estimated costs of each scenario from the baseline co sts. Exhibit 3 presents these results as total Exhibit 2

Calculations Used to Estimate Costs of Cu rrent Recordkeeping Requirements for UST System Repairs (Baseline)

Year Year from

End-of-Life of

UST System Annuitized Payments

Per UST Discounted Payments (7%)

Per UST Number of Recordkeeping

Events Per Year Costs Per

Year

Calculation A B C = (A x 18,875) D = (B x C)
1 20 $0.34 $0.34 377,500 $128,546
2 19 $0.34 $0.32 358,625 $114,130
3 18 $0.34 $0.30 339,750 $101,050
4 17 $0.34 $0.28 320,875 $89,192
5 16 $0.34 $0.26 302,000 $78,454
6 15 $0.34 $0.24 283,125 $68,739
7 14 $0.34 $0.23 264,250 $59,959
8 13 $0.34 $0.21 245,375 $52,034
9 12 $0.34 $0.20 226,500 $44,889
10 11 $0.34 $0.19 207,625 $38,456
11 10 $0.34 $0.17 188,750 $32,673
12 9 $0.34 $0.16 169,875 $27,482
13 8 $0.34 $0.15 151,000 $22,830
14 7 $0.34 $0.14 132,125 $18,670
15 6 $0.34 $0.13 113,250 $14,956
16 5 $0.34 $0.12 94,375 $11,648
17 4 $0.34 $0.12 75,500 $8,709
18 3 $0.34 $0.11 56,625 $6,104
19 2 $0.34 $0.10 37,750 $3,803
20 1 $0.34 $0.09 18,875 $1,777 Total Present Value Costs 3.86 3.86 $924,102

Total Annualized Costs $87,228DRAFT – DO NOT CITE OR QUOTE

6 

### costs over a 20-year period, annualized costs, an d annualized costs per facility (assuming 18,875 facilities) for each of the deregulatory scenarios. Under the three-year scenario, we estimate the total cost savings over 20 years to be near ly $887,200, the annualized cost savings to be approximately $83,700, and the annualized cost sa vings per facility at $4.43. Under the fiveyear scenario, we estimate the total cost savings over 20 years to be approximately $835,700, the annualized cost savings to be nearly $78,900, and th e annualized cost savings per facility at $4.17. Under the 10-year scenario, we estimate the total cost savings over 20 years to be nearly $631,700, the annualized cost savings to be approximately $59,600, and the annualized cost savings per facility at approximately $3.15.

Exhibit 3

Estimated Cost Savings Associated with Re duced Recordkeeping Requirements for Repairs

Total (20 Years) Annualized Annualized Per Facility (18,875 Facilities)
3-Year Option

Baseline Costs $924,102 $87,229 $4.62 Costs under deregulation $36,910 $3,484 $0.18 Cost Savings $887,193 $83,745 $4.43
5-Year Option Baseline Costs $924,102 $87,229 $4.62
Costs under deregulation $88,402 $8,345 $0.44 Cost Savings $835,700 $78,884 $4.17
10-Year Option
Baseline Costs $924,102 $87,229 $4.62 Costs under deregulation $292,422 $27,603 $1.46 Cost Savings $631,680 $59,626 $3.15DRAFT – DO NOT CITE OR QUOTE

7 

### Limitations

This analysis of cost savings associated with reducing the recordkeep ing time for UST system repairs is preliminary and is subj ect to several limitations, including:

• Because the ICR does not explicitly estimate th e cost of maintaining records for previous year repairs, we assume that the estimated cost represents the entire cost to maintain records for the lifetime of the UST system. If the ICR intended for the cost estimate to represent a yearly recordkeeping cost, th is analysis has underestimated the costs associated with recordkeeping and likely undere stimates the cost savings associated with each deregulatory scenario.

• This analysis assumes that repairs occur in th e first year of installation, when in fact repairs may occur throughout the lifetime of an UST system. As result, this analysis may overestimate costs associated with the baseline and deregulatory scenarios. Since the yearly cost depends on timing of the repa ir within the lifetime of the UST system, it is unclear how fluctuations in the timing of repairs would affect cost savings.

• As in the ICR, this analysis assumes a constant number of yearly repairs. In practice, the number of repairs likely fluctuates over time. Also, as the systems replaced in the late 1990s age, it is possible that the number of repairs will increase in the future. An increase in the number of repairs would result in higher cost savings associated with the deregulatory options. However, if impr ovements in technology have resulted in reductions in the number of annual repairs, this analysis would overestimate costs and cost saving attributed to the deregulatory options.

Reducing Recordkeeping Time for Leak Detection Results

Section 280.45 requires that owne rs and operators maintain reco rds that contain information about each release detection system in place at an UST system. Operators are required to maintain records regarding leak detection, including: 7



### • All performance claims about any leak detectio n system used must be kept for five years from the date of installation;

• Sampling, testing, or monitori ng results must be kept fo r one year (except for tank tightness testing results, which must be kept until the next test is conducted);

• Documentation of all calibrations, maintenance, and repairs must be kept for one year after servicing was completed; and

• Manufacturer calibration and maintenance schedule s must be kept for five years from the

date of installation.

7 Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures

, EPA ICR Number 1360.08DRAFT – DO NOT CITE OR QUOTE

8 

### Under EPA’s potential de regulatory option, we estimate the cost savings associated with reducing recordkeeping time for l eak detection results from one y ear to six consecutive months.

Methods, Assumptions, and Data Sources

ICR1360.08 provides cost burden information on the maintenance of records for release detection. The ICR estimates that each facility incurs costs of $37.61 per year to maintain

records related to release detection. 8 

### Since the ICR consolidates the cost burden across the various recordkeeping requirements noted above, t easing out the specific costs associated with maintenance of testing results is difficult. Ther efore, it is unclear how the costs differ between the various recordkeeping requirements. However, since most facilities have installed some form of leak detection equipment prior to the last five years (e.g., Section 280.40 requires that all tanks by December 1993 install leak detection), it is likely that relatively few facilities will be required to maintain records associated with performance claims and maintenance schedules within five years of installing le ak detection. In the ICR, EPA estimates the inst allation of 8,500 new USTs per year; this repres ents just 1.3 percent of the total UST universe (an average of 620,667 USTs over the period covered by the ICR). As a result, this scr eening-level analysis assumes that all recordkeeping costs occur from leak detection testing, which are currently required to be kept for a one-year period. Exhi bit 4 presents the key assumptions and data sources used to estimate the cost savings associated with reducing recordkeeping time for leak

detection results. 9

Exhibit 4

Key Assumptions and Data Sources Used to Estimate Cost Savings Associated wi th Reduced Recordkeeping

Time for Leak Detection. Assumption Data Source
Number of facilities required to maintain leak detection records 237,533 ICR 1360.08 Leak detection recordkeeping cost per facility $37.61 ICR 1360.08
Total leak detection recordkeeping costs per year a $8,933,616 ICR 1360.08 Total Leak detection cost per month $744,468 Estimated

Notes:

a Value does not match ICR due to rounding.



### Results

Exhibit 5 presents the baseline costs, deregul atory option costs, and potential cost savings associated with reduced recordkeeping time for leak detection results, in aggregate and per facility. We estimate total cost savings for th is deregulatory option to be approximately $4.5 million dollars per year and approximately $19 per facility.

8 As in the previous analysis, the ICR does not explicitly pr ovide estimate across multiple years of operation. As a result, we assume that the estimated co st represents the entire cost to maintain records entire period of time required in the regulations, which may vary from one to five years depending on the action.

9 Note that we do not include the potential cost of reading the regulations in these preliminary estimates.DRAFT – DO NOT CITE OR QUOTE

9 Exhibit 5

Estimated Cost Savings Associated with Reduced Recordkeeping Requirements for Leak Detection

Recordkeeping Time (months) Recordkeeping

Cost Per Month Annualized

Total Cost Annualized Cost Per Facility (237,533 Facilities)

Baseline 12 $744,468 $8,933,616 $37.61
Deregulatory Scenario 6 $744,468 $4,466,808 $18.81 Cost Savings $4,466,808 $18.81



### Limitations

The major limitation of this analysis is that we we re not able to separate out the costs of various leak detection recordkeeping requirements fr om the information available in ICR 1360.08. Because we assume all recordkeeping costs are a ssociated with leak detection results (as some portion of these costs are relate d to other recordkeep ing requirements), we may overestimate costs and cost savings associated with this deregulatory option.

Removing Corrosion Protection Requiremen ts for Safe Suction Steel Piping

UST piping conveys product through either a pressured system or through suction. 10 

### Section 280.2 requires that, wi th a few exceptions, all steel UST pipi ng have a corrosion-resistant coating and cathodic protection. EPA is investigating the cost savings associated with removing corrosion protection requirements for steel piping that use “safe” suction methods. 11



### To investigate the costs associated with inst alling or repairing corrosion protection on safe suction steel piping, IEc referenced I CR 1360.08, Thomson Publishing Company’s Underground Storage Tank Guide , OUST research conducted by E2 Environmental in 2006, along with additional outside resources. In addition, IEc conducted phone conversations with several UST installers from around the country to assess the ex tent to which safe suction steel piping is in

service.

Evidence suggests that establishing a baseline for the quantity of safe suction steel piping still in operation is difficult and the removal of corrosion pr otection for these pipes is not likely to result in significant cost savings for opera tors. This evidence includes:

• A lack of reliable estimates of the quantity of safe suction steel piping: ICR 1360.08 does not attempt to quantify the number safe suction steel pipes ex istence; however EPA does estimate that 90 percent of all piping is pressurized, leaving the remaining 10 percent as suction-based systems. With ava ilable resources, we were unable to locate a reliable estimate that indicates what percen tage of this 10 percent qualifies as “safe”

10 40 CFR Part 280.41(b)

11 Safe suction piping, also known as European piping, is designed with a slope so that pipe contents will drain back into the tank, if the suction is released. Alaska Department of Environmental Conservation. Underground Storage Tank Inspector Reference Handbook . March 2002.DRAFT – DO NOT CITE OR QUOTE

10 

### suction. 12 

### Furthermore, we could not locate reliab le estimates of the percentage of safe suction systems that employed steel piping.

• UST equipment installers indicate that use of safe suction steel piping is rare and declining: Discussions with the Petroleum Equi pment Institute (PEI) and member equipment installers suggest that most steel piping has been replaced by fiberglass or flexible piping. To the extent that steel pi pes remain, they are most likely found in rural areas. The installers indicated that they rarely encounter safe suction steel piping. 13 

### One

installer from the Midwest remarked that he updated the corrosion protection on safe suction steel piping at most, tw ice a year. He added that he recommends that all operators who encounter corrosion problems with steel pi ping replace it with fiberglass. As the majority of remaining steel pipes are at sma ll facilities with relatively short piping runs, the cost to upgrade to fiberglass is often competitive with restoring corrosion protection. 14 

### Therefore, most operators choose to replace steel piping with non-corrosive

materials.

• Prevalence of secondary co ntainment around piping: According to updated Underground Storage Tank Guide and recent research by E2 Environmental, at least 19 states require some form of secondary containment around UST piping. The UST

installers indicated that in areas where sec ondary containment is re quired, steel piping is virtually non-existent, as it was replaced to meet the secondary containment requirements. Furthermore, the installers suggest that even in states where secondary containment is not required, operators will typically choose to install double-walled piping when repairing, remodeling, or updating facilities to avoid li ability (and the added expense of additional testing th at is often required) associated with single-walled steel piping. 15

12 Regular or American suction which does not contain sloped piping, does not qualify under this deregulatory option.

13 Robert Renkes. Petroleum Equipment Institute. Personal Communication. June 2008; Duanne Grippe, O'Day Equipment LLC. Personal Communication. July 2008; Jerry Thomas. C.E. Thomas Company. July 2008.

14 Duanne Grippe, O'Day Equipment LLC. Personal Communication. July 2008.

15 The installers indicate that in the process of insta lling secondary containment around piping, operators will replace existing steel piping with do uble-walled fiberglass or flexible pi ping. Jerry Thomas. C.E. Thomas Company. July 2008.DRAFT – DO NOT CITE OR QUOTE

11 

### Attachment A: Calculations Used to Es timate Potential Costs of Recordkeeping Requirements for UST System Repairs

Exhibit A-1

Calculations Used to Estimate Potential Cost s of Recordkeeping Requirements for UST System Repairs Under 3-Year Scenario

Year Year from

End-of-Life of

UST System Annuitized Payments Per Facility Discounted Payments (7%)

Per Facility Number of Recordkeeping

Events Per Year Costs Per

Year

Calculation A B C = (A x 18,875) D = (B x C)
1 20 $0.34 $0.34 56,625 $19,282
2 19 $0.34 $0.32 37,750 $12,014
3 18 $0.34 $0.30 18,875 $5,614 Total Present Value Costs $36,910

Total Annualized Costs $3,484

Exhibit A-2

Calculations Used to Estimate Potential Cost s of Recordkeeping Requirements for UST System Repairs Under 5-Year Scenario

Year Year from

End-of-Life of

UST System Annuitized Payments Per Facility Discounted Payments (7%)

Per Facility Number of Recordkeeping

Events Per Year Costs Per

Year

Calculation A B C = (A x 18,875) D = (B x C)
1 20 $0.34 $0.34 94,375 $32,137
2 19 $0.34 $0.32 75,500 $24,027
3 18 $0.34 $0.30 56,625 $16,842
4 17 $0.34 $0.28 37,750 $10,493
5 16 $0.34 $0.26 18,875 $4,903 Total Present Value Costs $88,402

Total Annualized Costs $8,345DRAFT – DO NOT CITE OR QUOTE

12 Exhibit A-3

Calculations Used to Estimate Potential Cost s of Recordkeeping Requirements for UST System Repairs Under 10-Year Scenario

Year Year from

End-of-Life of

UST System Annuitized Payments Discounted Payments (7%) Number of Recordkeeping

Events Per Year Costs Per

Year

Calculation A B C = (A x 18,875) D = (B x C)
1 20 $0.34 $0.34 188,750 $64,273
2 19 $0.34 $0.32 169,875 $54,062
3 18 $0.34 $0.30 151,000 $44,911
4 17 $0.34 $0.28 132,125 $36,726
5 16 $0.34 $0.26 113,250 $29,420
6 15 $0.34 $0.24 94,375 $22,913
7 14 $0.34 $0.23 75,500 $17,131
8 13 $0.34 $0.21 56,625 $12,008
9 12 $0.34 $0.20 37,750 $7,482
10 11 $0.34 $0.19 18,875 $3,496

Total Present Valu e Costs $292,422

Total Annualized Costs $27,602