United States
         Environmental Protection
         Agency
Solid Waste And
Emergency Response
(OS-420) WF
500/B-92/001
April 1992
&EPA   Introduction to Leak
         Detection

         Understanding Federal
         Release Detection
         Requirements and Acceptable
         Release Detection Methods
          nstructor Manual
                               Printed on Recycled Paper


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                                   Contents
                                                                            Page


NOTES TO THE INSTRUCTOR	     vii


CHAPTER ONE: BASIC LEAK DETECTION	     1

      I.     OVERVIEW OF LEAKING UNDERGROUND STORAGE TANK SYSTEMS
            (USTs)	     1

            A.    The problem	     1
            B.    Releases	    2
            C.    Uses and ownership of USTs	     2

      II.     LEAK DETECTION	    3

            A.    What does leak detection accomplish?	     3
            B.    Why is leak detection necessary for owners and operators of USTs?	     3

      III.    LEAK DETECTION METHODS	    5

            A.    Internal leak detection methods	    5
            B.    Interstitial leak detection methods	     5
            C.    External leak detection methods	5
            D.    Piping monitoring	:	    6

      IV.    OTHERS SOURCES OF INFORMATION ON THE UST PROGRAM	     7

CHAPTER TWO: UST WALK-THROUGH	     1

      I.     WHAT IS AN UST?	     1
      II.     UST SYSTEM PARTS	    3

            A.    Tanks	    3
            B.    Piping	    3
            C.    Product dispensers	    4
            D.    The site	    5

CHAPTER THREE: SITE CHARACTERISTICS	     i

      I.     UST SYSTEM CHARACTERISTICS	    2

            A.    Tank age (new vs. existing)	    2
            B.    Tank size	     2
            C.    Piping system	    2
            D.    UST system size	    3

      II.     PRODUCT CHARACTERISTICS	    4

            A.    Types of stored product	    4
            B.    Characteristics of stored products	    5

                                         iii

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Contents

III.



IV.


V.


CHAPTER
1.




II.






III.


CHAPTER
1.


F
SOIL CONDITIONS: BACKFILL & SURROUNDING SOIL 	
A. Relative porosity 	
B. Hydraulic conductivity 	
C. Contamination 	
CLIMATIC FACTORS 	
A. Temperature 	
B. Rainfall 	
GEOLOGIC CONDITIONS 	
A. Effects of ground water 	
B. Important ground-water variables 	
FOUR: LEAK DETECTION METHODS FOR TANKS 	
GENERAL LEAK DETECTION REQUIREMENTS 	
A. Deadlines 	
B. Leak detection methods allowed 	
C. Requirements for probability of detection/probability of false alarm 	
D. Standard test procedures 	
LEAK DETECTION METHODS: MONTHLY MONITORING 	
A. Automatic tank gauging systems (ATGS) 	
B. Manual tank gauging (MTG) 	
C. Secondary containment with interstitial monitoring 	
D. Ground-water monitoring 	
E. Vapor monitoring systems 	
F. Statistical inventory reconciliation (SIR) 	
LEAK DETECTION METHOD: INVENTORY CONTROL & TIGHTNESS TESTING
A. Inventory control 	
B. Tank tightness testing 	
FIVE: LEAK DETECTION METHODS FOR UST PIPING 	 	 	
UST PIPING 	
A. Pressurized piping systems 	
B. Suction piping systems 	
'age
8
8
8
9
10
10
10
11
11
11
1
1
1
2
2
3
4
4
8
12
16
21
23A
24
24
29
1
1
1
1
    IV

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Contents

III.





III.


V.


V.




APPENDICES
1.
II.





III.

LEAK DETECTION FOR UST PIPING 	
A. Deadlines 	
B. Requirements 	
C. Methods 	
D. Requirements for PD/PFA 	
E. Standard test procedures 	
AUTOMATIC LINE LEAK DETECTORS 	
A. Automatic flow restrictors 	
B. Automatic flow shutoff devices 	
LINE TIGHTNESS TESTS 	
A. Direct volumetric line tightness test 	
B. Indirect line tightness test 	
MONTHLY MONITORING METHODS 	
A. Secondary containment with interstitial monitoring 	
B. Ground-water monitoring 	
C. Vapor monitoring 	
D. Statistical inventory reconciliation 	

GLOSSARY OF LEAK DETECTION TERMS 	
EXERCISES 	
A. Case Study Guideline 	
B. UST Site Characteristics 	
C. Automatic Tank Gauging Systems 	
D. Ground-Water Monitoring 	
E. Vapor Monitoring 	
SLIDE SECTION 	 	
Page
	 3
	 3
	 4
	 5
	 6
	 6
	 7
	 7
	 8
	 11
	 11
	 13
	 15
	 15
	 17
	 19
	 21

	 1-1
	 11-1
	 11-1
	 II-3
	 II-5
	 II-7
	 II-9
	 111-1

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VI

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                             NOTES TO THE INSTRUCTOR
       Welcome to "Introduction to Leak Detection." This course presents State and local UST program staff
with a review of acceptable methods of release detection. The training should enable them to understand
leak detection methods and to help UST owners and operators make an educated choice among leak detec-
tion course answers such questions as:

     .  •       What are the Federally accepted methods of leak detection?

       •       What are the requirements for monitoring USTs?

       •       What methods are used for leak detection in UST piping systems?

       •       What site characteristics should be considered when deciding on the proper leak detection
             •  method  for a certain UST?

       •       What are the advantages and the limitations of the various leak detection methods?

       •       How do each of the methods compare in operation and maintenance?

       These questions will be addressed by means of a variety of instructional methods:  class lectures,
slide presentations, large and small group discussions, question and answer sessions, and case study
exercises. As an instructor, you should be prepared to present the material in the course as well as to answer
the questions and address the concerns of your students. The course has been designed to give you numer-
ous opportunities to incorporate scenarios and examples that illustrate your experiences and  relate the course
material to situations unique to your locale. The more specific the information presented in this course, the
more effective the course will be.

Course Materials

       The materials in this package are designed to assist the instructor throughout the entire course.
Three types of materials  are provided: The instructor's manual' a student  manual1 and visual  aids such as text
slides, photographic slides, and graphic slides. You will also find a series  of illustrative exercises at the end of
the manual.  These resources will be sufficient for a complete training program, but it is suggested that you
incorporate other materials, as appropriate.

       The instructor's manual is arranged in a two-column format.  The left column contains the text of the
student manual. The right column provides space for your notes, as you are encourage to add State-specific
material and personal experience  anecdotes regarding leak  detection. The right column also provides
prompts for using the accompanying slides and exercises. (Slide material is described below; see Appendix II
for exercises.)

       To help you visually present the course, numerous slides are provided in the slide box that is part of
this training package.  Slides are numbered consecutively for each chapter.  Hard copies of each text and
graphic slide are provided in the "Slide Section," so you can  easily review  the slides as you tailor the course
to your needs.  Text slides act as prompts for both student and instructor by following the content of the
course in outline form. Graphic slides and  photo slides illustrate concepts and equipment being discussed.
(The "Slide Section" does not include hard  copies of the photo slides.) You are especially encouraged to
supplement the slides or replace them with others that are more appropriate for the situations your students
are most likely to encounter.
                                              vii

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       The student's manual is also arranged in a two-column format. The left column contains the
same text found in the left column of the instructor's manual.  The right column labeled 'Student
Notes' indicates only slide numbers; most of the column has been left blank to provide space for
notes. The student's manual also provides definitions of terms in a glossary, and hard copies of most
graphics.


Preparing to Deliver the Course

       Because instructors for this course will have various levels of teaching experience, the
following suggestions and teaching hints are provided to make teaching this course a more pleasant
and productive experience.  Keep in mind that these are suggestions and may be incorporated  into
the course  as you feel necessary.

       Effective instruction requires careful  preparation by the instructor.  The more familiar you are
with the course materials, the easier the delivery of the course will be.

       •       Study the instructor's and student's manuals.

       •       Review the reference materials, and select slides and other materials to assist you in
               your presentation. Remember that you are encouraged to incorporate supplemental
               materials specific to your State. Research for ideas, facts, and anecdotes that will
               apply to your situation.  (Examples of specific situations include coastal areas, where
               tides affect the water table, or areas with extreme temperature changes that may affect
               tank testing procedures).

       •       Practice your presentation and use of the visual aids.  Get a feel for the length of time
               that will be required to cover the material.  Remember to include time for questions.

       •       Make notes to yourself on items you want to cover that are not included in the
               manuals. It is very easy to forget to include something, once you have begun
               instruction.

       •       Contact  other instructors who have presented the course to learn from their
               experiences.

       •       You may choose to send out an advance registration form to participants requesting
               information on their work experience. This may help you to shape the course
               materials for a specific audience.

The following are suggestions you may want to consider just prior to delivery of the course:

       •       Prepare  and check all materials, training aids, and equipment needed  for  each class.
               Make sure that you have enough copies of the required materials for the number of
               students, and include a few  extra copies for late registrations.

       •       Check your meeting facilities for lights, heat, chair set-up, and anything else that might
               affect the comfort of the students while the course is being conducted.

       •       Review each chapter for its goals and objectives.
                                              VIII

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The following are suggestions to consider while giving the presentation:

       •      Make sure that all students can hear you, and that they can see the slides.

       •      Try to pace your speaking pattern.  A nervous instructor tends to talk too fast.  Taking
              a few deep breaths now and then will help.

       •      Introduce each new unit with an overview of what the student is going to learn.

       •      Close each unit with a brief overview of what was presented.

       •      Make sure to allow time for questions. You may decide to ask students to hold all
              questions until the end of a unit, or you may tell them that they may ask questions at
              any time.


Applicability of OUST Publications

       EPA's Office of Underground Storage Tanks (OUST) has developed many publications and
videos that you may find useful as training tools.  You will find a list of these materials at the end of
Chapter One.

       In addition, you should be aware of an additional resource not included on that list:  a series
of publications appearing under the general title of 'Standard Test Procedures for Evaluating Leak
Detection.' Each publication in the series presents a detailed, highly technical  procedure for testing
one of the leak detection  methods.  Each publication includes a form that can be used to verify that
the method being described meets EPA standards.  Although tank owners and government  regulators
are not likely to need the  actual, detailed test procedures, you may find some of the information
applicable to your training. The series includes the following:

       •      Automatic Tank Gauging Systems (45A)
       •      Liquid-Phase Out-of-Tank Product Detectors (45B)
       •      Non-Volumetric Tank Tightness Test Methods (45C)
       •      Pipeline Leak Detection Systems  (45D)
       •      Statistical Inventory Reconciliation Methods (45E)
       •      Vapor-Phase Out-of-Tank Product Detectors (45F)
       •      Volumetric Tank Tightness Test Methods (45G)
       •      Entire set of seven titles above (45SET)

The "Standard Test Procedures' series has been available in limited quantities since 1990 and there
may already be copies in your office.  If you need a copy, you can place an order (at no cost) by
using the order numbers  indicated above and sending your request to:

       U.S. Environmental Protection Agency
       Office of Underground Storage Tanks
       P.O. Box 6044
       Rockville, MD 20850


Questions and Feedback

       If you have questions or would like to comment on the contents of the training  package,
please contact the Office of Underground Storage Tanks, U.S. EPA, at (703) 308-8850.
                                              IX

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                                    CHAPTER ONE


                              BASIC LEAK DETECTION

This chapter will introduce you to the problem of leaking underground storage tanks, leak detection
and what it accomplishes, and why leak detection is necessary.  It will also provide an overview of
several leak detection methods. The chapter will serve as an introduction for some participants, and
as a review of the material for others with more experience. This information provides the background
necessary for understanding the following chapters.
               Lecture Notes
             Instructional Aids
     OVERVIEW OF LEAKING UNDERGROUND
     STORAGE TANK SYSTEMS (USTs)
     A.   The problem

         1.    Petroleum and chemicals are
              stored in underground storage
              tanks, many of which are vulner-
              able to corrosion.

                   84 percent of service station
                   tanks are made of bare
                   (unprotected) steel and are
                   highly susceptible to cor-
                   rosion.

                   15 - 20 percent of petroleum
                   tanks may be leaking, which
                   means that hundreds of
                   thousands of USTs may be
                   leaking.

         2.    Leaking tanks pose a threat to
              ground water. Releases from
              USTs into water supplies used for
              drinking and other purposes can
              endanger public health.

         3.    The threat of leaking tanks is not
              limited to ground water.  Other
              considerations are:

                   Contamination of surface
                   waters;
Slide 1: Chapter One slides.

Note: Each slide is numbered, and corresponds
to a specific section in the manual.

Note: Text in this column is designed to assist
you with talking points. You are encouraged to
incorporate scenarios and examples throughout
the course.

Slide 1A (photo):  Leaking tank.

Slide 2: This slide presents the topics to be
covered in Chapter One.
Slide 3 (graphic): This pie graph illustrates the
number of tanks that are unprotected, and there-
fore highly susceptible to corrosion.
Slide 4: Discuss the problem of leaking USTs.
Include specific numbers of the UST universe in
your area, and the specific types of health and
environmental threats that have resulted.
Slide 5: Discuss other risks associated with
leaking USTs.
Note: Although ground-water contamination is a
major concern, there are other problems that
have to be addressed.
                                                                        Chapter One, Page 1

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           Lecture Notes
                                              Instructional Aids
     4.
     Fires and explosions; and

     Toxic fumes that seep into
     homes and businesses.

Two components of gasoline,
benzene and ethyl dibromide, are
suspected cancer-causing
agents.
B.   Releases

     1.   Releases result from piping fail-
         ure, spills and overfills, and tank
         corrosion.

     2.   When a release occurs, product
         can:

              Seep through the soil into
              the ground water;

              Float on top of the water
              table;

              Discharge into wells or sur-
              face water; and/or

              Seep into underground
              structures (pipelines, utilities,
              lines, basements, etc.).

C.   Uses and ownership of USTs

     1.   The largest percentage (39 per-
         cent) of regulated USTs are used
         in retail motor fuel businesses.

     2.   The second largest user of USTs
         (38 percent) is the non-retail
         motor fuel sector, such as rental
         companies and government
         agencies.

     3.   Nearly 80 percent of all USTs
         used to store petroleum are
         owned and operated by gas sta-
         tions and industry. Government
         and farmers each own about half
         of the remaining 20 percent.
         Farm tanks with a capacity of
         1,100 gallons or less used for
         storing motor fuel for noncommer-
         cial purposes are not subject to
         Federal UST regulations.
                                 Slide 6: Discuss the three types of releases
                                 mentioned. Most of the releases occur due to
                                 piping failures.
                                 Slide 7 (graphic):  Use this graphic to point out
                                 the ways that released product can travel.
                                 Slide 8 (graphic): Use this pie chart to discuss
                                 the uses of regulated USTs. Note that the larg-
                                 est percentage of USTs contain motor fuels.
                                 This course will focus on these tanks.
                                 Slide 9 (graphic): Use this pie chart to discuss
                                 the ownership of the petroleum USTs.
                                                                     Chapter One, Page 2

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               Lecture Notes
             Instructional Aids
II.   LEAK DETECTION

     A.   What does leak detection
         accomplish?

         1.   Leak detection warns owners and
              operators of leaks in tanks and
              piping. Early warning enables
              owners and operators to take
              action to stop the escape of large
              amounts of the product into the
              environment.

         2.   Leak detection can prevent
              ground-water contamination.

     B.   Why Is leak detection necessary for
         owners and operators of USTs?

         1.   Detecting leaks is a good busi-
              ness practice.

                   Loss of product costs the
                   owner/operator money.

                   Extensive releases can be
                   very costly to clean up.

                   USTs that pollute a com-
                   munity's environment can
                   cause public relations prob-
                   lems.

         2.   Detecting leaks protects human
              health and the environment.

                   Leak detection helps prevent
                   the contamination of ground
                   water that may be used as
                   drinking water. Half of the
                   U.S. population relies on
                   ground water as a source of
                   drinking water.

                   Petroleum and chemicals
                   stored in USTs can con-
                   taminate the soil, air and
                   water with harmful effects to
                   people, plants, and animals,
                   particularly in farm produc-
                   tion.
Slide 9A (photo): Current headlines demon-
strate the increasing amount of public aware-
ness.
Slide 10:  Discuss the effects of leak detection:
it warns the owner/operator of leaks and pre-
vents environmental contamination and risks to
human health.
Slide 11:  Emphasize the cost benefits of leak
detection.

Note:  The average cost of a cleanup now is
$150,000.

Slide 12:  Discuss the four main reasons for leak
detection.
Note:  Many service stations want to promote
good public relations and avoid bad publicity.
Leak detection demonstrates to the community
that the owner/operator is concerned about
safety.
                                                                         Chapter One, Page 3

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 Lecture Notes
Instructional Aids
     Leaking tanks also can lead
     to explosions, fires, toxic
     fumes, and contaminated
     surface waters.

Detecting leaks can protect
owners and operators against
liability suits.

     Local  residents and com-
     munities can take damage
     claims to court.

Detecting leaks is required by
Federal, State, and local laws.

     LIST regulations require
     preventing, detecting, and
     cleaning up leaks and spills.
                                                            Chapter One, Page 4

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                Lecture Notes
           Instructional Aids
III.    LEAK DETECTION METHODS

      Three types of methods detect leaks from
      tanks:

—    Internal monitoring:

—    Interstitial monitoring; and

—    External monitoring.

      In addition, piping has special leak detection
      requirements.

A.    Internal leak detection methods

      These methods monitor inside the tank to
      check for leaks, and frequently measure
      volume loss over time of test. There are four
      types of internal monitoring:

1.     Inventory control combined with tightness
      testing;

2.     Manual tank gauging;

3.     Automatic tank gauging; and

4.     Statistical inventory reconciliation.

B.    Interstitial leak detection methods

      These methods monitor the area between the
      tank and a containment barrier.

C.    External leak detection methods

      These methods use sensors to monitor the
      environment surrounding the tank for the
      presence of the leaked product. There are two
      types of external monitoring:

1.     Vapor mon itoring; and

2.     Ground-water monitoring.
Slide 13: There are three main types of leak de-
     tection. Each method will be discussed in
     detail during the remaining chapters of the
     course.
Note: A video is available that reviews each type
     of leak detection except for statistical
     inventory reconciliation. For information on
     ordering this 25-minute video, "Straight
     Talk on Leak Detection with Joe Thursday,"
     see the publication list and order form at
     the end of this chapter. You may want to
     show the video in lieu of this portion of the
     chapter.
Slide 14: Discuss these methods briefly.
Slide 15: Discuss briefly.
Slide 16: Discuss briefly.
                                                                          Chapter One, Page 5

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           Lecture Notes
             Instructional Aids
D.   Piping monitoring

     1.    Requirements for pressurized
          piping and suction piping are not
          the same.

              Compliance deadlines; and

              Testing requirements.

     2.    Pressurized piping must have
          automatic line leak detectors to
          prevent catastrophic releases.

     3.    There are three types of leak
          detection for piping:

              Tightness testing;

              Interstitial monitoring; and

              External monitoring.
Slide 17:  Mention the differences between
these types of piping systems.
Slide 18:  Mention that the methods of leak
detection are generally the same as those for
tanks, but piping may be tested either as part of
the whole tank system, or separately.
                                                                      Chapter One, Page 6

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               Lecture Notes
            Instructional Aids
IV.  OTHER SOURCES OF INFORMATION ON
    THE UST PROGRAM

    In addition to the materials in this manual,
    the UST program also has developed hand-
    books, slide shows, and video tapes on a
    wide range of topics to inform States, local-
    ities and regulated industries about the
    regulations and program requirements.
    Many of these materials may be of interest
    to you.

    Additional information sources have been
    provided for you on the next few pages of
    this manual, including  publication and video
    order forms and a list of UST Regional and
    State contacts.

    In addition to these materials, the EPA
    RCRA/Superfund Hotline (1-800-424-9346)
    can assist you with specific questions about
    the UST regulatory requirements.
Slide 19: Use this slide to review the chapter.
Remind students that each method will be dis-
cussed in detail, for both tanks and piping.
                                                                        Chapter One, Page 7

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             U.S. ENVIRONMENTAL PROTECTION AGENCY

             OFFICE OF UNDERGROUND STORAGE TANKS
                                     PUBLICATIONS LIST


General Information                                                         ORDER NO.

Notification for Underground Storage Tanks: EPA Form 7530-1 (Revised 9-88)	5
Hazardous Substance List	7
Here Lies the Problem	39
LUSTLINE Bulletin	10
Normas y Procedimientos para T.S.A. (Spanish version of Musts for USTs, an Overview of Federal
    Technical UST Standards)	26S
Managing Underground Storage Tanks (brochure to order a slide show)	 40
Straight Talk on Tanks (Leak Detection Summaries)	49
"Oh No! Leaks and Spills!" - First Response (brochure)	73
Leak Lookout (External Leak Detectors)	74
Introducing Reg-ln-A-Box (ordering flier)	84


Regulations

Notification of Requirements for Owners of Underground Storage Tanks; Final Rule 40 CFR Part 280
   (Federal Register 11/8/85)	3
Underground Storage Tanks: Technical Requirements and State Program Approval; Final Rule 40 CFR
   Parts 280 & 281 (Federal Register Part II9/23/88)	 4A
Underground Storage Tanks Containing Petroleum; Financial Responsibility Requirements and State Program
   Approval Objective; Final Rule 40 CFR Parts 280 & 281  (Federal Register Part I110/26/88), Underground
   Storage Tanks Containing Petroleum; Financial Responsibility Requirements; Interim Final Rule 40 CFR
   Part 280 (Federal Register 11/9/89, 5/2/90)	4B
Hazardous Waste; Interim Prohibition Against Installation of Unprotected Underground Storage Tanks;
   Interpretive Rule 40 CFR Part 280 (Federal Register 6/4/86)	17
Subtitle I. Hazardous and Solid Waste Amendments of 1984; RCRA   	21


Technical Reports

Causes of Release From UST Systems	32
Tank Corrosion Study	42
Estimating Air Emissions from Petroleum UST Cleanups  .	88
Detecting Leaks. Successful Methods Step-by-Step	92


ORDER FORM
  Name:	Title:.

  Organization:	

  Street:	
  City:	State:	Zip:.

  Telephone: (	)	-	
     Please return this form to:

         U.S. Environmental Protection Agency
         Office of Underground Storage Tanks
         P.O. Box 6044
         Rockville, MD 20850
Please send me the
publications I have circled:

3  4A  4B  5   7

10 17  21  26S  32

39 40  42  49  73

74 84  88  92
                                                                                      UST25
                                                                                6/17/91 SPEC

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                              Other Publications of Interest
TITLE/STOCK NO.
    COST
AVAILABLE FROM
Musts for USTs: A Summary of the Regulations for
Underground Storage Tank Systems
Stock No. 055-000-00294-1

Dollars and Sense: A Summary of the Financial
Responsibility Regulations for Underground Storage
Tank Systems
Stock No. 055-000-00293-2

Cleanup of Releases from Petroleum USTs: Selected
Technologies
Stock No. 055-000-00272-0

Field Measurements: Dependable Data When You Need It
Stock No. 055-000-00368-8

Petroleum Tank Releases Under Control: A Compendium
of Current Practices for State UST Inspectors
Stock No. 055-000-00295-9

Survey of Vendors of External Petroleum Leak Monitoring
Devices for Use with USTs
Stock No. 055-000-00277-1
    $2.50



    $1.25




    $7.50



    $5.50


    $8.50



    $4.25
Superintendent of Documents
U.S. Government Printing Office
Washington, D.C.  20402
(202) 783-3238

Visa and MasterCard accepted
Evaluation of Volumetric Leak Detection Methods for
Underground Fuel Storage Tanks
Volume 1.  No. PB89-124333     paper/microfiche
Volume 2.  No. PB89-124341     paper/microfiche

Underground Storage Tank Corrective Action
Technologies
PB 87-171278                  paper/microfiche
              National Technical Information Service
              5285 Port Royal Road
$39.00/$8.00   Springfield, VA 22161
$81.00/$21.50  (703) 487-4600
$31.00/$8.00
Soil Gas Sensing for Detection and Mapping of Volatile
Organlcs
Catalog No. TO49
   $35.007     National Water Well Association
   member     P.O. Box 182039, Dept. 017
   $43.757     Columbus, OH 43218
 non-member   (614) 761 -1711
Reg-ln-A-Box personal computer (PC) software is an           $5.00
aid to understanding and working with the Federal UST       plus shipping
regulations. Easy to use and available for PC-compatibles    and handling
with hard disk drives. Not copy protected.
              Public Brand Software
              1-800^426-3475 (24 hours a day)
              (317)856-7571 (in Indiana)
              Visa and MasterCard accepted
Volumetric Tank Testing (Summary of Edison Study
on Internal Leak Detectors)
Stock No. 625/9-89/009
    Free
Center for Environmental Research
  Information
26 West Martin Luther King Drive
Cincinnati, OH 45268-1072          I
(513) 569-7562

                       6/17/91 SPEC

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                                   Audiovisual  Programs
  DEOS
AVAILABLE FROM
"Straight Talk on Leak Detection"
(An introductory overview for owners and operators of underground storage tank
systems on the leak detection methods available for complying with LIST
regulations [Total 35 minutes].)
Part 1: Straight Talk From Tank Owners. (Owners address the problems of
       LIST compliance [5 minutes].)
Part 2: Straight Talk on Leak Detection with Joe Thursday (30 minutes).
                                                 Cost: $40.00 prepaid

"Doing It Right"
(Proper installation of underground tanks and piping for installation crews.)
Part 1: Tanks (24 minutes)
Part 2: Piping (16 minutes)
                                                 Cost: $16.00 prepaid
Environmental Media Center
P.O. Box 30212
Bethesda, MD 20814

OR CALL TOLL FREE:
1-800-522-0362
(301-229-1944 in Maryland)

Visa and MasterCard accepted
"Searching for the Honest Tank: A Guide to LIST Facility Compliance
Inspections"
(Covers major steps of UST inspections from protocols and equipment to
enforcement and followup; from cathodic protection to leak detection.  Although
  is directed at inspectors, the video is also helpful to owners and operators
   minutes].)
                               Video and Booklet Cost:   $40.00 prepaid
                                         Booklet Cost:    $5.00 prepaid
New England Interstate
  Environmental Training Center
Attn: VIDEOS
2 Fort Road
South Portland, ME 04106
"Tank Closure Without Tears: An Inspector's Safety Guide"
(Focuses on problem of explosive vapors and safe tank removal.)
                                Video and Booklet Cost:  $30.00 prepaid
                                         Booklet Cost:   $5.00 prepaid
"What Do We Have Here? An Inspector's Guide to Site Assessment at
Tank Closure."
(A three-part video on inspecting sites for contamination where tanks have been
removed.)
Part 1: Site Assessment Overview (30 minutes)
Part 2: Field Testing Instruments at a Glance (14 minutes)
Part 3: Soil and Water Sampling at a Glance (7 minutes)
                               Video and Booklet Cost:  $45.00 prepaid
                                         Booklet Cost:   $5.00 prepaid
"A Question of When: Tank Installation for Inspectors"
(Tank and pipe installation with a checklist for inspectors [28 minutes].)
                                                Cost:   $32.85 prepaid

"In Your Own Backyard"
(What tank owners should require from installation contractors [22 minutes].)
                                                Cost:   $32.85 prepaid
TZ Communications
P.O. Box 332
Holbrook, MA 02343
                                                                                           6/17/91 SPEC

-------
                                  Audiovisual Programs
SLIDES                                                              AVAILABLE FROM
"Managing Underground Storage Tanks"                                  National Audiovisual Center
(Segments on all phases of tank management from inventory and installation to     Customer Services Section/WD
leak detection and clean up.) 185 slides, 27-page script, and 103 pages of         8700 Edgeworth Drive
graphics.                                                               Capitol Heights, MD 20743-3701
                                               Cost: $120.00           (301)763-1891
"Tank Talk: The New National Rules"                                      Capital Presentations
(A visual overview of the Federal rules for USTs - - technical standards and        10 Post Office Road - Suite 2N
financial responsibility.) 70 slides, 20-page script, and 30-minute narrated          Silver Spring, MD 20910
audio tape.                                                             (301)588-9540
                                               Cost:  $80.00
                                                                                        6/17/91 SPEC

-------
                     U.S. Environmental Protection Agency
                     Office of Underground Storage Tanks

                  Regional and State UST/LUST Program Contacts
                         HI
                         Guam
                         Am. Samoa   LJ
                         CNMI
William Torrey
U.S. EPA, Region 1
JFK Federal Building
Mailcode: HPU-7
Boston, MA 02203
617-573-9604
FTS 833-1604

Dit Cheung
U.S. EPA, Region 2
Hazardous & Solid Waste
Programs Branch
26 Federal Plaza
Code: 2AWM-HSWPB
New York, NY 10278
212-264-3384
FTS 264-3384

Renee Gruber, Acting
U.S. EPA, Region 3
  J1 Chestnut Building
  lilcode: 3HW63
Philadelphia, PA 19107
215-597-7354
FTS 597-3177
                        EPA Regional UST Program Managers
John Mason
U.S. EPA, Region 4
345 Courtland St.. N.E.
Mailcode: 4WM-GWP-15
Atlanta, GA 30365
404-347-3866
FTS 257-3866

Gerald Phillips
U.S. EPA, Region 5
77 W. Jackson Blvd.
Mailcode: HRU-8J
Chicago, IL 60604
312-886-6159
FTS 886-6159

Samuel Coleman, Acting
U.S. EPA, Region 6
1445 Ross Avenue
Mailcode: 6H-A
Dallas, TX 75202-2733
214-655-6755
FTS 255-6755
Lee Daniels
U.S. EPA, Region 7
RCRA/STPG Branch
726 Minnesota Avenue
Kansas City, KS 66101
913-551-7055
FTS 276-7055

Debbie Ehlert
U.S. EPA, Region 8
999 18th Street
Mailcode: 8-HWM-WM
Denver, CO 80202-2466
303-293-1514
FTS 330-1514
Pat Eklund
U.S. EPA, Region 9
75 Hawthorne Street
10th Floor, H-2-1
San Francisco, CA 94105
415-744-2079
FTS 484-2079

Joan Cabreza
U.S. EPA, Region 10
1200 Sixth Avenue
Mailcode: WD-139
Seattle, WA 98101
206-553-1643
FTS 399-1643
                                                                                           UST93
                                                                                            3/92

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                                     State UST/LUST Program  Offices
AL
AR
AZ
CA
    ^UST/LUST CONTACT2
    .AK Dept of Environmental Conservation
     Contaminated Sites
     410 Willoughby Avenue, Suite 105
     Juneau.AK 99801-1795   907-465-5250

     UST/LUST CONTACT
    '•AL Dept. of Environmental Management •
     Ground-Water Section/Water Division
     1751 Congressman W. L. Dickinson Dr.
    . Montgomery, AL 36130
                        UST: 205-271-7986
                       LUST: 205-271-7834

     UST/LUST CONTACT1
     AR Dept. of Pollution Control & Ecology
     Regulated Storage Tank Division
     P.O. Box8913,72219-8913
     8001 National Drive
     Little Rock, AR 72219-8913
                             501-562-6533
     UST/LUST CONTACT2
    . AZ Department of Environmental Quality
     3033 North Central Avenue
     Phoenix, AZ 85004         602-257-6984

     UST/LUST CONTACT
     CA State Water Resources Control Board
     Division of Clean Water Program
     201 4 T Street
    .(P.O. Box 944212, Zip: 94244-2120)
    ISacramento, CA 95814
                        UST: 9 16-739-4436
                       LUST: 916-739-4317
     UST CONTACT
     CO State Oil Inspection Office
     1001 East 62nd Avenue, Room A1
     Denver, CO 802 1 6         303-289-5643

     LUST CONTACT
     CO Department of Health
     Hazardous Materials & Waste Mgmt. Div.
     Underground Storage Tank Program
     4210 East 11th Avenue
     Denver. CO 80220         303-331-4864

     UST/LUST CONTACT2
     CT Dept. of Environmental Protection
     Underground Storage Tank Program
     165 Capitol Avenue
     Hartford, CT 06106        203-566-4630
     UST/LUST CONTACT2
     DC Environmental Regulatory Admin.
     Underground Storage Tank Branch
     2100 Martin Luther King Ave. S.E.
     Suite 203
     Washington, D.C. 20020
                             202-404-1167
DE   UST/LUST CONTACT2
     DE Dept. of Natural Resources &
        Environmental Control
     Underground Storage Tank Branch
     715Grantham Lane
     Newcastle, DE 19720     302-323-4588
CO
CT
DC
FL   UST/LUST CONTACT2
     FL Dept. of Environmental Regulation
     Tank Section           •
     Twin Towers Office Building - Rm 403
     2600 Blair Stone Road
     Tallahassee, FL 32399-2400
                             904-488-3935
GA  UST/LUST CONTACT1
     GA Department of Natural Resources
    -• Underground Storage Tank Mgmt. Prog.
     4244 International Parkway, Suite 100
     Atlanta, GA 30354         404-362-2687

HI   UST/LUST CONTACT1
     HI Department of Health
     Solid and Hazardous Waste Branch
     500 Ala Moana Blvd., Suite 250
     Honolulu, HI 96813-4913   808-586-4230

IA   UST/LUST CONTACT1
     IA Department of Natural Resources
     Henry A. Wallace Building
     900 East Grand
     Des Moines, IA 50319     515-281-8135

ID   UST/LUST CONTACT2
     ID Department of Health & Welfare
     ID Division of Environmental Quality
     1410 North Hilton
     Boise, ID  83706          208-334-5860

IL   UST CONTACT
     IL Office of State Fire Marshal
     Division of Petroleum & Chemical Safety
     1035 Stephenson Dr.
     Springfield, IL 62703       217-785-5878

     LUST CONTACT
     IL EPA, Bureau of Land
     Div. of Remediation Mgmt., LUST Section
     P.O. Box 19276
     Springfield, IL 62794-9276  217-782-6760

IN   UST CONTACT
     IN Dept. of Fire and Services
     Office of the State Fire Marshal
     402 West Washington Street
     Room C241
     Indianapolis, IN 46204     317-232-2222

     LUST CONTACT
     IN Dept. of Environmental Management
     Office of Environmental Response
     2321 Executive Drive
     Indianapolis, IN 46241     317-243-5110

KS  UST/LUST CONTACT
     KS Department of Health & Environment
     Bureau of Environmental Remediation
     Underground  Storage Tank Section
     Forbes Field,  Building  740
     Topeka, KS 66620-0001
                         UST: 913-296-1685
                        LUST: 913-296-1684
                                                                                    KY
LA
                                                                                    MA
                                                                                     MD
                                                                                     ME
                                                                                     Ml
                                                                                     MN
UST/LUST CONTACT1
KY Division of Waste Management
Underground Storage Tank Branch
18 Reilly Road
Frankfort, KY 40601        502-564-6716

UST/LUST CONTACT2
LA Dept. of Environmental Quality
Underground Storage Tank Division
P.O. Box 82178, 7290 Bluebonnet
Baton Rouge, LA 70884-2178
                        504-765-0243
UST CONTACT
MA Department of Public Safety
Underground Storage Tank Program
P.O. Box 490, East Street, Bldg. #5
Tewksbury, MA 01876     508-851-9813

LUST CONTACT
MA Dept. of Environmental Protection
One Winter Street
Boston. MA 02108         617-556-1044

UST/LUST CONTACT1
MD Department of Environment
Hazardous & Solid Waste Mgmt. Admin.
Underground Storage Tank Program
2500 Broening Highway
Baltimore, MD 21224      410-631-3442

UST/LUST CONTACT1
ME Dept. of Environmental Protection
State House - Station 17
Hospital Street, Ray  Building
Augusta, ME 04333       207-289-2651

UST CONTACT
Ml Department of State Police
Fire Marshal Division
P.O. Box 30157
                                                                                     MO
                                                                                          Lansing, Ml 48909
                             517-322-1935
     LUST CONTACT
     Ml Department of Natural Resources
     Leaking Underground Storage Tank Unit
     P.O. Box 30028
     Lansing, Ml 48909         517-373-8168

     UST/LUST CONTACT
     MN Pollution Control Agency
     Underground Storage Tank Program
     520 Lafayette Road North
     St. Paul, MN 55155-3898
                         UST: 612-297-8609
                       LUST: 612-297-8574
     UST CONTACT
     MO Department of Natural Resources
     Water Pollution Control Program
     P.O. Box 176
     Jefferson City, MO 65102   314-751-6822

     LUST CONTACT
     MO Department of Natural Resources
     Environmental Services Program
     P.O. Box 176
     Jefferson City, MO 65102   314-526-3349
    State has 1 person serving as both the UST and LUST Contact.
2 = State has 1 UST and 1 LUST Contact; both have the same address and telephone number.
                                                                                                                        3/92

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                                      State UST/LUST Program Offices
 MS   UST/LUST CONTACT1
 . ... „ MS-Department of Environmental Quality •...t
•  -  Bureau of Pollution Control     ••  • ••
      Underground Storage Tank Section
      P.O.  Box 10385
      Jackson, MS 39289-0385
                             601-961-5171
 MT   UST/LUST CONTACT1
      MI Dept. of Health & Environ. Science
      Solid & Hazardous Waste Bureau
      Cogswell Building - UST Program
      Helena, MT 59620        406-444-5970

 NC   UST/LUST CONTACT2
      NC Pollution Control Branch
      Division of Environmental Management
      Dept. of Env. Health & Natural Resources
      441 N. Harrington St.
      Raleigh. NC 27603        919-733-8486

 ND   UST/LUST CONTACT1
      ND Department of Health
      Division of Waste Management
  > ••' Box'5520,1200 Missouri Ave:,'Roomv302"
      Bismarck, ND 58502-5520
                             701-221-5166
 NE   UST  CONTACT
      NE State Fire Marshal's Office
      Flammable Liquid Storage Tank Division
      246 South 14th Street
      Lincoln, NE 68508        402-471-9465

      LUST CONTACT
      NE Dept. of Environmental Control
      GroundwaterSect., Water Quality Division
      301 Centennial Mall South, Box 98922
      Lincoln, NE 68509-8922    402-471-4230

 NH   UST/LUST CONTACT1
      NH Dept. of Environmental Services
      Oil Compliance Section
      Groundwater Protection  Bureau
      6 Hazen Drive, P.O. Box 95
      Concord, NH 03301       603-271-3644

 NJ   UST/LUST CONTACT2
      NJ Dept. of Environmental Protection
        and Energy
      Responsible Party Site Remediation
      401 East State Street (CN-029)
      Trenton, NJ 08625        609-984-3156

 NM   UST/LUST CONTACT1
      NM Environment Department
      Underground Storage Tank Bureau
      P.O.  Box 26110
      1190 St. Francis Drive
      Harold Runnels Building, Room N2150
      Santa Fe, NM 87502      505-827-0188

 NV   UST/LUST CONTACT1
      NV Dept. of Conservation & Natural Res.
      Division of Environmental Protection
- •. -,,., Capitol  Complex
      123W.  NyeLane
      Carson City, NV 89710     702-687-5872
NY  UST/LUST CONTACT1
 .-. '. NY Dept of Environmental Conservation
     Bulk Storage •Section          •
     50 Wolf Road, Room 326.
     Albany, NY 12233-3520    518-457-4351

OH  UST/LUST CONTACT2
     OH Department of Commerce
   .-8895 East Main Street
    • P.O. Box 687
  .  • Reynoldsburg, OH 43068
                             614-752-7938
OK  UST/LUST CONTACT
     OK Corporation Commission      •  :  •
     Underground Storage Tank Program
     Jim Thorpe Building
     2101  North Lincoln Blvd.
     Oklahoma City, OK  73105
                        UST: 405-521-3107
                       LUST: 405-521-6575
OR  UST CONTACT
     OR Dept. of Environmental Quality
     Underground Storage Tanks
	  811 SW Sixth Avenue, 7th Floor
     Portland, OR 97204       503-229-5733

     LUST CONTACT
     OR Dept. of Environmental Quality
     UST Cleanup Program
     811 SW Sixth Avenue, 9th Floor
     Portland, OR 97204        503-229-6170

PA  UST/LUST CONTACT2
     PA Dept. of Environmental Resources
     BWQM, Storage Tank Program
     3600 Vartan Way, 2nd Floor
     P.O. Box 8762
     Harrisburg, PA 17105-8762
                             717-657-4080
Rl   UST/LUST CONTACT1
     Rl Dept. of Environmental Management
     Underground Storage Tank Section
     291 Promenade St.
     Providence. Rl 02908      401-277-2234

SC  UST/LUST CONTACT
     SC Dept of Health and Environ. Control
     Ground-Water Protection Division
     2600 Bull Street
     Columbia, SC 29201
                        UST: 803-734-5335
                       LUST: 803-734-5331

SD  UST/LUST CONTACT1
     SD Dept. of Environ. & Natural Resources
     Division of Environmental Regulation
     523 East Capitol
     Joe Foss Building
     Pierre, SD 57501-3181     605-773-3351

TN  UST/LUST CONTACT1
     TN Dept. of Environment & Conservation
     200 Doctors Building
     706 Church Street
     Nashville, TN 37243-1541   615-741-4081
TX   UST/LUST CONTACT1
    - Texas Water Commission   • • '•
     Petroleum Storage Tank Division
     P.O. Box 13087, Capitol Station
     1700 North Congress
     Austin, TX 78711-3087     512-371-6200

UT   UST/LUST CONTACT1 -
     UT Dept of Environmental Quality
     Bureau of Solid & Hazardous Waste
   -  Division of Environmental Response and
        Remediation
     1950 West North Temple
    • Salt Lake City, UT 84116   801-538-4100

VA   UST/LUST CONTACT
     VA State Water Control Board
     P.O. Box 11143
     Richmond, VA 23230-1143
                        UST: 804-527-5192
                       LUST: 804-527-5188

VT   UST/LUST CONTACT1
     VT Dept of Natural Resources
     Underground Storage Tank Program
     103 South Main Street, West Building
     Waterbury, VT 05676-0404
                             802-244-8702
WA  UST CONTACT
     WA Department of Ecology
     P.O. Box 47655
     Olympia, WA 98504-7655   206-459-

     LUST CONTACT
     WA Department of Ecology
     P.O. Box 47600
     Olympia. WA 98504-7600   206-438-7164

Wl   UST CONTACT
  - • Wl Dept. of Industry, Labor & Human
         Relations
     Bureau of Petroleum Insp. & Fire Protection
     P.O. Box 7969
     201 East Washington Avenue
     Madison. Wl 53702        608-266-7605

     LUST CONTACT
     Wl Department of Natural Resources
     P.O. Box 7921
     Madison, Wl 53707-7921    608-267-7560

WV  UST/LUST CONTACT2
     WV Division of Natural Resources
     Waste Management Section
     UST/LUST Office
     1356 Hansford Street
    • Charleston, WV 25301      304-348-6371

WY  UST/LUST CONTACT1
     WY Dept. of Environmental Quality
     Water Quality Division
     Herschler Building, 4th Floor West
     122 West 25th Street
     Cheyenne, WY 82002      307-777-7781
1 = State has 1 person serving as both the UST and LUST Contact.
2 - State has 1 UST and 1 LUST Contact; both have the same address and telephone number.
                                                                                                                        3/92

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                                    State  UST/LUST Program Offices
     ERRITORIES
AS  UST/LUST CONTACT1              :
     AS Environmental Protection Agency
     Office of the Governor
   •  American Samoa Government
     ATTN: UST/LUST Program
    > Pago Pago, American Samoa 96799
                            684-633-2304
CNMI UST/LUST CONTACT1
     Division of Environmental Quality
     P.O. Box 1304, Dr. Torres Hospital
     Commonwealth of Northern Mariana Ids
     Saipan, MP 96950        607-234-6984
GU  UST/LUST CONTACT1
     GU Environmental Protection Agency
     IT&E
    • Harmon Plaza, Complex Unit D-107
     130 Rojas Street
     Harmon, Guam 96911      671-646-8863

PR   UST/LUST CONTACT1
     Water Quality Control
     Environmental Quality Board
     P.O. Box 11488
     Commonwealth of Puerto Rico
     Santurce, Puerto Rico 00910
                            809-767-8109
VI   UST/LUST CONTACT1
     Environmental Protection Division
     Dept. of Planning and Natural Resources
     Suite 321, Nisky Center
     45A Estate Nisky
     Charlotte Amalie
     St. Thomas, Virgin Islands 00802
                            809-774-3320
	  state has 1 person serving as both the LIST and LUST Contact.
2 = State has 1 UST and 1 LUST Contact; both have the same address and telephone number.
                                                                                                                   3/92

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                                    CHAPTER TWO
                                UST WALK-THROUGH
This chapter will walk you through an underground storage tank (UST) system, including the tanks,
the piping systems, and the product dispensers.  The chapter will also introduce frequently used site
terminology, such as excavation zone and water table. This information will serve as a background for
following chapters on site characteristics and leak detection methods for tanks and piping systems.
               Lecture Notes
             Instructional Aids
Understanding the different parts of an UST sys-
tem allows you to better evaluate the leak detec-
tion requirements and the various leak detection
methods available.  This chapter describes  a
typical UST system and each of its major com-
ponents.
I.    WHAT IS AN UST?

•«    Underground Storage Tank (UST) refers to
     a system storing petroleum products or
     hazardous substances. An UST system for
     motor fuel includes the tank(s), piping, and
     product dispensers.  At least 10 percent of
     the combined volume of the tank(s) and
     associated piping must be underground for
     the system to be considered an UST sys-
     tem.

     Although multi-tank service station USTs are
     among the most common tank systems,
     and provide the basis for this course, it is
     important to recognize that there are several
     other systems, including used oil tanks,
     single-tank systems, farm tanks, and tanks
     without piping.

•«    With the following exceptions, underground
     tanks must comply with Federal UST regula-
     tions:

         Farm or residential tanks of 1,100 gal-
         lons or less storing motor fuel for non-
         commercial purposes;

         Tanks storing heating oil for consump-
         tive use on the premises where stored;

         Tanks holding 110 gallons or less;
Introduce the chapter, describing the material to
be covered as it is mentioned in the introduction.

Slide 1: Chapter Two slides.
Slide 2: Define an UST system, including tank,
piping, and dispenser.

Slides 3 and 3A (graphic and photo): Typical
Retail Gasoline Station.  Shows petroleum tanks,
piping, and dispensers.

Note: (<) Draws attention to basic Federal re-
quirements for UST systems.  You should note
that State and local requirements may be more
stringent.
Note: This course focuses on the service
station system; however, you should mention
that there are other tank types.  Mention those
which may be most common in your area.
Slide 4: Discuss these exceptions to Federal
UST regulations.
                                                                        Chapter Two, Page 1

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      Lecture Notes
             Instructional Aids
Tanks on or above the floor of under-
ground areas, such as basements or
tunnels;

Septic tanks and systems for collecting
storm water and wastewater;

Flow-through process tanks;

Emergency spill and overfill tanks; and

Surface impoundments, ponds, pits, or
lagoons.
Slide 5: Exceptions to Federal UST regulations.
                                                               Chapter Two, Page 2

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                Lecture Notes
             Instructional Aids
II.    UST SYSTEM PARTS
     A.   Tanks
          1.   Typical retail tanks have a
              capacity of 2,000 to 12,000 gal-
              lons.

                   Older tanks typically hold
                   2,000-6,000 gallons.

                   Newer tanks generally hold
                   6,000-12,000 gallons.

          2.   New tanks are generally con-
              structed of cathodically protected
              coated steel, fiberglass-reinforced
              plastic (FRP), or a steel-fiberglass
              composite.
     B.   Piping
          1.   Product delivery lines connect the
              tanks and product dispensers.

                   Because delivery lines are
                   generally installed near the
                   ground surface and have
                   many connections, leaks
                   often come from delivery
                   lines.

          2.   Manifolded piping typically refers
              to a fueling system in which two
              or more dispensers are supplied
              with product via a piping system
              that is connected to one or more
              tanks. Manifolded systems have
              multiple connections and are thus
              particularly susceptible to piping
              failures.

                   An example of manifolded
                   piping is a single submer-
                   sible pump in an UST which
                   supplies three separate
                   dispensers.
Slide 6: Use this text slide to discuss charac-
teristics of regulated tanks.

Slide 6A (photo):  Most older tanks are unpro-
tected; however, regulations require protection.

Note: There may be some exceptions to the
type of tanks encountered, such as partially
buried tanks, lift tanks, separators, and older
tanks made of concrete. Discuss other tank
types that are found in your State.

Slide 6B (photo):  Newer tank types include
cathodically protected coated steel, fiberglass,
and fiberglass reinforced plastic (FRP) and steel
composites.

Slide 6C (photo):  Steel - FRP composite.
Slide 6D (photo):  Discuss areas of concern for
each type of piping (i.e., where joints commonly
leak and which flex connectors and swing joints
are susceptible to damage).
                                                                           Chapter Two, Page 3

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           Lecture Notes
                                              Instructional Aids
     5.
         Vent pipes are routed from the
         tank to the surface as above-
         ground vents.

         --   Vent pipes allow product
              fumes to be vented from the
              tank into the atmosphere,
              thus reducing the risk of
              explosion from volatile fumes
              under pressure.

         Fill pipes usually connect the
         underground tank to an above-
         ground fitting where a tank truck
         connects its transfer hose.

              These pipes are used to fill
              the tank with the product.

              Remote fills have the poten-
              tial to leak.
Vapor recovery lines are pipes
that convey petroleum vapors
back to the tank truck during off-
loading or back to the UST during
dispensing of product.  In Stage II
vapor recovery, there will be twice
as much piping in the UST sys-
tem because pipes run from dis-
penser back to tank.
C.   Product dispensers
         A pumping system draws or
         pushes product through the pro-
         duct delivery lines to a delivery
         hose, which dispenses the pro-
         duct.

         At retail stations, meters attached
         to product dispensers measure
         the volume of product dispensed
         from the UST system.
                                 Slide 6E (photo): Vent pipes.
                                 Slide 6F (photo):  Fill box.
Discuss when remote fills are used. They often
pose special problems because they are
installed as an 'afterthought."

Slide 7: Define vapor recovery lines.

Discuss vapor recovery lines and Stage II, if it is
used in areas of your State.
                                                                     Chapter Two, Page 4

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           Lecture Notes
             Instructional Aids
D.   The site
     1.    Excavation zone is the entire area
          that must be dug up in order to
          install an LIST.

     2.    Backfill is any material used to fill
          in the excavation zone after the
          tank is in place.

               Manufacturers' suggestions
               should be followed regard-
               ing the proper backfill to be
               used (generally,  crushed
               rock, pea  gravel, or sand).

     3.    Water table is the level where
          ground water will rest in porous
          soil conditions under normal
          atmospheric pressure.
Slide 8: Explain each of these terms and use
the following graphic to point them out.

Slide 9 (graphic): Point out each of the terms
discussed in Slide 8.

Explain that ideally the backfill should meet
specifications, but may  in reality be local soil,
contaminated soil, etc.  Describe problems you
may have seen that resulted from improper
backfill.
                                           Slide 10 (Review/Wrap Up):  This is a repeat of
                                           Slide 1, to be used as a review of what you have
                                           covered.  Mention the main topics discussed.
                                           Use this time to answer any questions or to dis-
                                           cuss specific UST systems.
                                                                     Chapter Two, Page 5

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                                   CHAPTER THREE
                              SITE CHARACTERISTICS
What are the Important site characteristics that should be considered when selecting the proper
leak detection method? This chapter will introduce you to relevant UST system characteristics,
product characteristics, soil conditions, climatic factors, and geologic conditions.  An understanding of
these factors will help you assist UST owners and operators in making a more informed decision
about the leak detection methods that can be used with particular UST systems.
               Lecture Notes
             Instructional Aids
Choosing the appropriate leak detection method
for a particular UST system requires understan-
ding how site characteristics can vary. The basic
factors to consider when selecting a leak detec-
tion method fall into five groups:

     I.   UST system characteristics;

     II.   Product characteristics;

     III.  Soil conditions;

     IV.  Climatic factors; and

     V.   Geologic conditions.
Slide 1: Chapter Three slides.

Slide 2: Use this slide to introduce the chapter,
explaining that an understanding of the following
site characteristics will assist the UST staff mem-
ber to work with the owners/operators to deter-
mine the most  appropriate leak detection
method for their UST system. Explain that
students will be asked to participate in an exer-
cise at the end of the chapter to review the
material and check  for understanding.
                                                                       Chapter Three, Page 1

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               Lecture Notes
             Instructional Aids
I.    UST SYSTEM CHARACTERISTICS
     A.   Tank age (new vs. existing)

         1.   New tanks are those installed
              after December 23, 1988.  Exist-
              ing tanks are those installed
              before December 23,1988.

         2.   Leak detection compliance dead-
              lines differ for new and existing
              tanks.

         3.   Some leak detection methods can
              be used only for 10 years  after
              installation of a new UST or
              upgrade of an existing UST.

         4.   Some leak detection methods are
              better suited for new tanks, while
              others easily can be incorporated
              into existing tank systems.

     B.   Tank size

         1.   Certain leak detection methods
              cannot be used with tanks larger
              than a specified capacity.

     C.   Piping system

         1.   Types of piping systems

                   Suction piping systems use
                   a vacuum to draw the pro-
                   duct from the tank to the
                   dispenser.

                   Pressurized piping systems
                   use a pump at the bottom of
                   the tank  to push the product
                   to the dispenser.

         2.   Leak detection requirements for
              piping differ based on the type of
              piping system used.
Slide 3:  This slide is an overview of UST system
characteristics, each of which will be discussed.

Slide 4:  There are different compliance dead-
lines for existing tanks - those installed before
December 23,1988, and new tanks - those
installed after December 23, 1988.
Slide 5 (graphic):  Phase-in schedule for com-
pliance with Federal UST regulations.
Slide 6: The size of the tank may limit the selec-
tion of leak detection methods involving manual
tank gauging, automatic tank gauging systems,
and some tank tightness tests.
Slide 7:  Briefly describe the two types of piping.
These types will be discussed in detail in Chap-
ter Five.
                                                                        Chapter Three, Page 2

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           Lecture Notes
             Instructional Aids
D.   UST system size

     1.   Number of tanks
Slide 8: Discuss both the numbers of tanks,
and the extent of the site area. These variables
may  be important when selecting a leak detec-
tion method.
              Some leak detection
              methods may be better
              suited or less costly than
              other methods for systems
              with many tanks.
     2.   Extent of site area
Slide 9: (This slide has been deleted.)
              Some leak detection
              methods may be more effec-
              tive or less costly for UST
              systems that cover a large
              area.
                                                                   Chapter Three, Page 3

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               Lecture Notes
             Instructional Aids
II.   PRODUCT CHARACTERISTICS

     A.   Types of stored product

         Stored products fall into two general
         groups: petroleum products and some
         hazardous substances.

         1.   Petroleum products (major types):

                   Gasoline and blends;

                   Diesel fuel;

                   Aviation fuel;

                   Kerosene;

                   Heating oil; and

                   Used oil.

         2.   Hazardous substances:

                   CERCLA (Superfund) hazar-
                   dous substances are subject
                   to LIST regulations.  For
                   example, ferric chloride, lead
                   iodide, and zinc  nitrate are
                   hazardous substances.

                   CERCLA hazardous sub-
                   stances require secondary
                   containment unless it can be
                   proved that another method
                   will work.  This course does
                   not equip you to determine if
                   other methods are sufficient.

                   RCRA hazardous wastes are
                   not subject to LIST regula-
                   tions because they are
                   under different regulations.
                   (See 40 CFR Parts 260-270
                   for hazardous waste regula-
                   tions.)
Slide 10:  Discuss the most common types of
stored products, as well as other products that
workers may encounter. Mention that this
course is geared towards petroleum products;
however, other products may be stored.

Characteristics of the products are discussed
individually below in Section B.
Discuss the hazardous substances that are
stored, and which of these are covered by the
regulations.

Note:  It is important to stress to students that
this course is designed to inform them about
leak detection methods, but it will not prepare
them to determine if a method is suitable for
hazardous substances.  Secondary containment
with interstitial monitoring is the only method that
is always suitable for hazardous substances.
This will be discussed further in Chapter Four.
                                                                        Chapter Three, Page 4

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           Lecture Notes
             Instructional Aids
B.   Characteristics of stored products

     Traits of different products may render
     certain leak detection methods inap-
     propriate.  Important characteristics
     include:

          Solubility;

          Density;

          Viscosity;

     --    Volatility;

          Thermal effects; and

          Compatibility with tank and piping
          materials.

     1.    Solubility

              Solubility  is the ability of a
              substance to dissolve in or
              mix with another substance.
              For example, alcohol mixes
              more easily  with water than
              oil does.

              This characteristic is impor-
              tant to know because if the
              product mixes easily with
              water, some methods may
              not easily be able to detect
              its presence (for example,
              ground-water monitoring).

     2.    Density

              Density refers to the mass of
              a given substance per unit
              volume.

              If the density of the product
              is higher than that of water,
              the product may sink
              beneath the ground-water
              surface and is not easily
              detectable.  Therefore,
              ground-water monitoring is
              not allowed  for these sub-
              stances.
Slide 11:  Product characteristics.
Slide 12:  Define solubility. Use examples to
help clarify. For example, alcohol in water is
soluble; oil in water is much less soluble.
Slide 13:  Define density.  The density of a
material will determine whether it floats or sinks.
Slide 14:  Gasoline floats on ground water;
dense non-aqueous phase liquids (DNAPLs) do
not.
                                                                     Chapter Three, Page 5

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      Lecture Notes
             Instructional Aids
3.   Viscosity

          Viscosity is a measurement
          of the ease with which a
          liquid flows (for example,
          molasses vs. water).

          The degree of  viscosity
          varies with changes in
          temperature.

          A product's viscosity may
          affect which method is suit-
          able  (for example, whether
          tank  testing can be con-
          ducted, ground-water moni-
          toring is effective, automatic
          tank  gauging can be used).

4.   Volatility

          Volatility refers to how
          readily a substance will
          vaporize.

          Volatility of the product may
          affect the use of certain leak
          detection methods.  For
          example, a product must
          vaporize easily if it is to be
          detected in vapor monitoring
          wells.

5.   Thermal effects

          Thermal effects refer to
          changes  in  product charac-
          teristics that occur in
          response to an increase or
          decrease in temperature.

          Density, viscosity, and
          volatility are product charac-
          teristics that are affected by
          temperature.

          For example, lower tempera-
          tures reduce the volatility of
          a product. As  a result,
          vapor monitoring can be
          affected at sites storing a
          product that does not
          vaporize well at low temper-
          atures.
Slide 15: Define viscosity. Tell students to
imagine water flowing vs. molasses flowing.
Slide 16:  Define volatility. Certain materials
evaporate much easier than others. Use gaso-
line vs. heating oil to clarify.
Slide 17:  Thermal effects are of particular con-
cern in areas of extreme temperatures, or areas
that experience large temperature variations.
Discuss how other characteristics change with
temperature.
                                                                Chapter Three, Page 6

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      Lecture Notes
Instructional Aids
         Temperature changes can
         affect the volume of a pro-
         duct. Monitoring methods
         that measure volume need
         to account for changes in
         volume created by tempera-
         ture changes.

6.    Compatibility

         Compatibility refers to the
         chemical effects stored pro-
         ducts may have on tank
         materials.

         Certain fuel blends (metha-
         nol and ethanol) and
         hazardous substances may
         not be compatible with the
         tank and piping material or
         tank lining, causing them to
         degrade.

         A tank owner storing these
         materials should check with
         the manufacturer to ensure
         that they are compatible with
         the tank and piping.
                                                              Chapter Three, Page 7

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                Lecture Notes
             Instructional Aids
III.   SOIL CONDITIONS:  BACKFILL &
     SURROUNDING SOIL
     A.    Relative porosity

          1.   Relative porosity refers to a
              measurement of the extent to
              which a material (for example, soil
              or backfill) contains small spaces
              through which vapors or liquids
              can pass.

          2.   Higher porosity backfill materials
              allow product vapors and liquids
              to pass through with greater
              ease.

          3.   Methods that monitor the environ-
              ment around the tank for signs of
              the leaked product require higher
              porosity backfills. New backfill
              that meets codes would meet
              porosity requirements.  Older
              backfill needs to be tested for
              porosity to gauge whether
              porosity is sufficient for external
              methods to detect leaks quickly.

     B.    Hydraulic conductivity

          1.   Hydraulic conductivity refers to a
              measurement of the rate at which
              a liquid (for example, water) can
              flow through a material such as
              soil.

          2.   Some materials can have high
              porosities but low hydraulic con-
              ductivity; thus, both measure-
              ments should be considered.

          3.   The presence of backfill materials
              with low hydraulic conductivity
              (for example, clay) generally pre-
              cludes the use of leak detection
              methods that monitor the environ-
              ment around the tank and piping.
Slide 18:  There are three soil characteristics
that we will discuss:  porosity, hydraulic conduc-
tivity, and  contamination.

Slide 19:  Define porosity. .
Slide 20 (graphic):  This graph shows the effect
of soil conditions (porosity and moisture) on
vapor concentrations.  Note that the readings
were taken the same distance from the free pro-
duct, at the same time. A low porosity, high
moisture soil can mask the vapors detected, so
certain detection methods may require greater
well spacing.
Slide 21:  Define hydraulic conductivity.  Explain
that this and porosity need to be considered.  It
is possible to have a high porosity with low con-
ductivity. (The pores may be large, but not con-
nected, so fluid cannot travel through.)
For example, clay has significant void space
(high porosity), but low conductivity.
Conductivity may also be affected by karst
topography or utility conduits.
                                                                         Chapter Three, Page 8

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           Lecture Notes
             Instructional Aids
C.   Contamination

     1.   Soil or backfill may be con-
         taminated by past releases (for
         example, leaks, spills, or overfills).

     2.   Some methods of leak detection
         would sense this past con-
         tamination and inaccurately signal
         a current leak.
Slide 22:  Mention problems that can occur due
to previously contaminated soil or backfill. Tests
may incorrectly indicate a leak even when there
is no problem with the UST system.
                                          Review soil conditions. Answer questions.
                                                                    Chapter Three, Page 9

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               Lecture Notes
             Instructional Aids
IV.   CLIMATIC FACTORS

     A.   Temperature
         1.    Extreme temperatures or dramatic
              changes in temperature may
              affect the accuracy of certain leak
              detection methods, and may
              render other methods ineffective.
Slide 23:  Both temperature and amount of rain-
fall may affect results obtained by certain leak
detection methods.  Discuss how these factors
may be a problem in your State.
     B.   Rainfall
         1.    Sites subject to heavy rainfall may
              experience significant changes in
              ground-water levels.

                   Fluctuating ground-water
                   levels may affect the
                   accuracy of ground-water
                   monitoring, and vapor
                   monitoring.
                                                                      Chapter Three, Page 10

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                Lecture Notes
             Instructional Aids
V.   GEOLOGIC CONDITIONS
     A.   Effects of ground water

          1.   The level of ground water relative
              to the tank's product level and
              the location of the 'hole" can
              affect both the rate and direction
              of a leak.  If ground water is high-
              er than the product level  inside a
              tank, ground water will generally
              flow into the tank.  If the product
              level is higher than the ground-
              water level, the product will gen-
              erally flow out of the tank. By
              influencing both the rate  and
              direction of a leak, the level and
              density of ground water relative to
              the level and density of the pro-
              duct in a tank can mask a leak.
              To detect leaks in this situation,
              monitoring devices need  to be
              used that can detect water in the
              tank.

     B.   Important ground-water variables

          1.   Depth  of water table

                   The water table depth may
                   affect the accuracy of vapor
                   and ground-water monitor-
                   ing.

          2.   Large fluctuations in the water
              table levels affect the  accuracy of
              vapor and ground-water monitor-
              ing methods.

          3.   Gradient of ground-water flow

                   If the gradient is steep, and
                   the monitoring wells are not
                   properly placed,  ground-
                   water flow may bypass the
                   monitoring wells and the
                   release may not  be
                   detected.
Slide 24:  There are also ground-water con-
ditions to consider.

Slide 25:  Discuss how the presence of ground
water can mask a leak.

Slide 26 (graphic):  Use this diagram to explain
how ground water can slow a leak by exerting
pressure on the tank, or increase the volume by
seeping into the tank.
Slide 27:  The depth and gradient of the water
table may influence the leak detection method
used. Stress problems that this causes in your
area, especially in areas of a fluctuating water
table (e.g., tidal areas).
Explain that with a steep gradient, the free pro-
duct may flow in a single, narrow path, thus
missing a well.  With a gentle gradient, the pro-
duct may flow slower and spread out more hori-
zontally, thus having a greater chance of being
detected by the well.  (Have students envision
water flowing down a steeply versus a slightly
sloped pane of glass.)
                                                                        Chapter Three, Page 11

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Lecture Notes
Instructional Aids
                                Slide 28:  Use this slide as a review to show
                                what material has been covered in the chapter.
                                Ask if there are any questions or specific char-
                                acteristics that they wish to discuss further.


                                Hand out the exercise on UST Site Characteris-
                                tics from Appendix II.  Have students work either
                                individually or in small groups. Allow 10-15
                                minutes (or more if necessary).  Then go over
                                the questions with students in a group. Make
                                sure that any State-specific questions that might
                                be helpful are covered. A sample list of ques-
                                tions also is included in Appendix II.
                                                         Chapter Three, Page 12

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                                  CHAPTER FOUR
                    LEAK DETECTION  METHODS FOR TANKS
How can you assist the owner or operator to select the right leak detection method for a specific
UST? This chapter describes several methods that meet the Federal requirements for leak detection.
This chapter's descriptions, considerations, and limitations noted for each system can help you assist
owners and operators in choosing the best leak detection system for their particular facilities.  The
chapter is divided into three parts: Part I notes some general leak detection requirements, Part II deals
with monthly monitoring methods, and Part III  treats the temporary leak detection method of tank
tightness testing and inventory control.
               Lecture Notes
                                     Instructional Aids
     GENERAL LEAK DETECTION
     REQUIREMENTS

     A.   Deadlines

         1.    New tanks
                  Tanks installed after Decem-
                  ber 23,1988, must comply
                  with UST leak detection
                  requirements when
                  Installed.
         2.    Existing tanks
                  Tanks installed before
                  December 23,1988, must
                  comply with UST leak detec-
                  tion requirements according
                  to the following timetable:
      Installation
        Date
Must Compty
  By
      Before 1965
      1966 -1969
      1970-1974
      1975 - 1979
      1980-1988
  December 1989
  December 1990
  December 1991
  December 1992
  December 1993
         Or if installation date is unknown.
                         Slide 1:  Chapter Four slides.

                         Slide 2:  Use this slide to introduce the chapter.
                         Mention that each method will be discussed in
                         detail in the chapter, including how it works, its
                         applicability, and special considerations.

                         Slide 2A (graphic photo):  Leak detection alter-
                         natives.

                         Slide 3:  Remind students that deadlines will
                         have to be met according to the date of tank
                         installation. A 'new tank is one installed after
                         December 1988.
                         Note:  Remind students that the (<) represents
                         basic Federal regulations.
                                             Slide 4:  Review compliance dates.
                                                                      Chapter Four, Page 1

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                 Lecture Notes
          Instructional Aids
B.    Leak detection methods allowed

1.    New tanks require one of the following:

—    Monthly monitoring; or

—    Monthly inventory control with tank tightness
      testing every five years.  This option can be
      used only for ten years after installation.

2.    Existing tanks require one of the following:

—    Monthly monitoring; or

—    Monthly inventory control and annual tank
      tightness testing.  This option can be used
      only until December 1998; or

—    Monthly inventory control and tank tightness
      testing every five years.  This option can be
      used only for ten years after a tank has
      been upgraded with spill/overflow
     prevention devices and corrosion protection.

C.    Requirements for probability of
      detection/probability of false alarm (PO/
      PFA)

1.    Some leak detection methods (tank or
      piping tightness testing, automatic tank
      gauging systems, statistical inventory
      reconciliation, and automatic line leak
      detectors) must be capable  of detecting
      the leak rate or quantity specified for that
      method with a probability of detection (PD)
      of 0.95 and a probability of false alarm
      (PFA) of 0.05.

      There are two PD/PFA compliance
      deadlines:

—    By December1! 990, automatic tank
      gauging systems, statistical inventory
      reconciliation, and tightness tests for tanks
      or piping must meet PD/PFA
      requirements;

—    By September 1991, automatic line leak
      detectors must meet PD/PFA requirements.
Slides 5 and 6: Discuss new tank require-
ments. Point out the differences between
new tank requirements and those for existing
tanks.
Note that monthly inventory control with tank
tightness testing can be used only for ten
years after installation or upgrade (or until
December 1998 for tanks without upgrade).
Slide 7: Discuss PD/PFA "95 and 5"
requirements.
                                                                          Chapter Four, Page 2

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               Lecture Notes
Instructional Aids
     However, methods permanently installed
     before the applicable compliance deadline
     are not required to meet the PD/PFA
     requirements.

D.   Standard test procedures

     EPA has developed standard test
     procedures (also known as protocols) that
     enable manufacturers of release detection
     methods and third-party evaluators of those
     methods to demonstrate that the methods
     can meet the Federal release detection
     requirements.  Results form these highly
     technical testing procedures can be
     summarized on a short form provided with
     each test procedure. Having summarized
    ^-test results, -manufacturers can distribute the
     forms to tank owners and State and local
     regulators, who can use them to verify that
     the method being described meets EPA's
     release detection standards.

     As of January 1992, EPA has published
     seven standard test procedures:

—   Volumetric tank tightness test methods;

—   Non-volumentric tank tightness test
      methods;

—   Automatic tank gauging systems;

—   Liquid-phase out-of-tank product detectors;

—   Vapor-phase out-of-tank product detectors;

—   Statistical inventory reconciliation methods;
     and

—   Pipeline leak detection systems.

     Your course instructor can tell you more
     about these published standard test
     procedures and how to get copies of them.
                                                                          Chapter Four, Page 3

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               Lecture Notes
             Instructional Aids
II.    LEAK DETECTION METHODS:  MONTHLY
     MONITORING

     Federal regulations describe five acceptable
     monthly monitoring methods:

         Automatic tank gauging systems;

         Manual tank gauging;

         Secondary containment with interstitial
         monitoring;

         Ground-water monitoring; and

         Vapor monitoring.

     The following sections briefly describe each
     method, discuss the conditions suitable for
     a method's application, and point out the
     major factors owners and operators should
     consider when selecting a method.

     A.   Automatic tank gauging systems
         (ATGS)

         1.    How ATGS work

         Automatic tank gauging systems con-
         tinuously measure and record product
         level  and temperature within the tank
         to  determine the change in  volume
         over  time.  If there is a significant loss
         of  volume, then there may be a leak.

              Each tank is equipped with a
              probe to measure product level
              and temperature.

              Underground wiring connects the
              tank with a monitor and micropro-
              cessor to record data read by
              probe:

                  Product level;

                  Water level; and

                  Temperature.
Slide 8:  Each of these methods will be
discussed in this chapter.

Note:  Place emphasis on the methods that are
most commonly used in your area.

Note:  Remind students that these methods are
conducted at least monthly.
Slide 9: Each method is discussed within the
following structure:  how the method works;
when the method is appropriate; and con-
siderations for owners/operators.
Slide 9A (graphic photo): ATGS introduction.

Slide 10: The first method is ATGS.
ATGS continuously measure product level, water
level, and temperature in the tank.

Slide 10A (graphic photo):  Facility layout show-
ing ATGS.
The sensors continuously measure the product
in the tank. If there is a significant loss of
volume that cannot be accounted for due to
temperature change, a leak may be indicated.

Slide 11 (graphic): Use this graphic to point
out the various parts of an ATGS.  Point out that
the probe is inside the tank.

Slide 11A  (photo):  ATGS probe installed into a
tank.

Slide 11B  (photo):  ATGS remote monitor.  Point
out readings that can be obtained from the mon-
itor.

Slide 11C  (photo):  ATGS remote monitor.
                                                                       Chapter Four, Page 4

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 Lecture Notes
             Instructional Aids
A leak is indicated if recorded
temperature changes cannot
account for the measured volume
change.

ATGS must be able to detect 0.2
gal/h release from any portion of
the tank that routinely contains
product.

ATGS have two modes,  and the
same equipment performs both
operations:

     Inventory control; and

     Leak testing.

a.    Inventory control mode

     This mode automatically
     records activities of an
     in-service tank, including
     deliveries.

          Product level  and tem-
          perature readings are
          taken automatically and
          computer converts
          them to volume meas-
          urements.

          ATGS operate in this
          mode whenever leak
          test mode is not being
          performed.

     In most systems, a probe
     measures water levels in the
     bottom of the tank and con-
     verts to a volume, which is
     used in inventory control.
     The probe can also indicate
     a leak of ground water into
     the tank.

     For most ATGS, on-site staff
     must manually record
     dispenser information.
Slide 12: There are two modes of operation of
an ATGS.
Slide 13 (graphic):  Based on this flow chart,
discuss activities and procedures for setting up,
monitoring, and analyzing data with an ATGS.

Slide 14:  Discuss how an ATGS works; that the
tank has a dedicated opening for the ATGS and
measurements are automatically taken and con-
verted into volume.
Mention that these are typical characteristics of
ATGS, and that systems will vary according to
manufacturer.
                                                          Chapter Four, Page 5

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      Lecture Notes
                                             Instructional Aids
2.
     Many systems have alarms
     to alert on-site staff of:

          High and low product
          levels;

          High water levels inside
          tank; and

          Theft.

b.   Leak testing mode

     Product level and tempera-
     ture are measured generally
     at least two hours a month
     in out-of-service tanks, usu- •
     ally at night.  The test can
     be set to last a given length
     of time.

          The frequency of meas-
          urements and length of
          test is determined by
          the manufacturer to
          meet PD/PFA require-
          ments and the regula-
          tory performance stan-
          dard of 0.2 gal/hr, and
          are programmed into
          ATGS. Generally, the
          longer the test is con-
          ducted, the higher the
          performance level of
          the test.

          Test can be run with
          any level of product in
          the tank.

          The temperature and
          product level readings
          are taken automatically.

When automatic tank gauging
systems are appropriate

a.   UST  system characteristics

     ATGS are used primarily on
     tanks smaller than 15,000
     gallons.
                                     Slide 15:  Discuss ATGS Alarm Systems.
                                     Slide 16:  Discuss how the leak testing mode
                                     works. The longer the test is conducted, the
                                     more accurate the results will be.
Slides 17 and 18:
appropriate.
Discuss when ATGS are
                                                               Chapter Four, Page 6

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 Lecture Notes
             Instructional Aids
     ATGS cannot be used for
     piping.

b.    Product characteristics

     To date ATGS used mostly
     with gasoline or diesel tanks
     because service stations
     have been the primary
     ATGS users.

     If other products are to be
     tested, owner/operator
     should ascertain that ATGS
     meets regulatory per-
     formance standards when
     used with that product.

c.    Soil conditions

     Use of ATGS is not
     restricted by soil type.

d.    Climatic factors

     Wait at least six hours
     between delivery and testing
     to stabilize temperature dif-
     ferences between added
     product and product already
     in tank. The wait time may
     vary due to climate.

e.    Geologic conditions

     If the ground water is high
     enough to cover a hole in a
     leaking tank, a leak may be
     masked and water may
     enter the tank.

     Therefore, ATGS should
     have water sensors with
     alarms, so that they can
     monitor for an increase in
     water as well as a decrease
     in the level of product.
Note:  For each leak detection method the dis-
cussion will go through each of the site charac-
teristics from Chapter Three.
Slide 19 (graphic):  This graphic helps explain
why at least a six-hour waiting period is neces-
sary.  Newly added product causes chaos within
the normal tank product stratification (layering).
Once the product has re-stratified, tests can be
conducted, achieving more accurate results.
The left side of the graph represents tempera-
ture.  The horizontal axis represents the number
of hours.  Note how the temperature layers "calm
down."

Slide 20 (graphic):  Use this graphic to explain
how changing levels in ground water can affect
test results. High ground water can mask a leak
or allow water into the tank.

Slide 20A (graphic photo):  Sample results from
an ATGS.
                                                           Chapter Four, Page 7

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           Lecture Notes
             Instructional Aids
     3.   Considerations

              No product should be
              delivered to the tank for at
              least six hours before the
              monthly test, to allow the
              temperature to stabilize.

              No withdrawal should be
              made from the tank for a few
              hours prior to testing.  With-
              drawals disturb the stratified
              layers in the tank, which  can
              lead to inaccurate test
              results.

              No product withdrawals or
              deliveries can be made
              during the monthly test
              which lasts one to six hours
              or more, depending on the
              manufacturers' recommen-
              dation.

              ATGS automation reduces
              time that employees must
              spend in monitoring leak
              detection.

              Inventory control and poten-
              tial off-site monitoring
              features are attractive to
              some owners and operators.

              Tanks require a dedicated
              opening for the ATGS
              probe, making retrofit dif-
              ficult in some cases.

B.   Manual tank gauging (MTG)

     1.   How MTG works

         MTG is a short-term test in a
         static (i.e., closed) tank.  It cannot
         be used for tanks larger than
         2,000 gallons.

         a.   It differs from  inventory con-
              trol, which requires daily
              recording of volume in an
              active tank, and keeping
              track of additions and with-
              drawals.
Slides 21 and 22:  Discuss the other considera-
tions for the use of ATGS.
Hand out exercise on ATGS from Appendix II.
Discuss as a group once students have had the
opportunity to work through the problem.
Slide 23:  Note that MTG can be used only on
small tanks (under 2001 gallons). Describe MTG
and explain that this method must be conducted
in a static tank, and must last 36 to 58 hours,
depending on the size of the tank.
                                                                    Chapter Four, Page 8

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 Lecture Notes
             Instructional Aids
b.   With MTG, weekly measure-
     ments of product levels are
     taken with a gauge stick
     inserted in the tank through
     the fill pipe.

c.   A test is conducted once
     each week and lasts at least
     36 hours.

d.   The UST must not be in use
     between measurements (no
     product can be added or
     withdrawn during this test
     period).

e.   Four measurements must be
     taken:

     Two at beginning of the
     weekly test; and

     Two at end of the weekly
     test.

f.    A calibration chart specific
     to the tank is used to con-
     vert product level measure-
     ment into product volume.
g.   The average of the final two
     measurements is subtracted
     from the average of the first
     two to obtain the change in
     product volume over time.

h.   The calculated product
     volume change is compared
     to weekly and monthly stan-
     dards (below,  in gallons). If
     the volume change exceeds
     these standards, the tank
     may be leaking. (The
     monthly figure is a simple
     average of the weekly
     measurements.)
Slide 23A (photo): Person using a gauge stick.
Slide 24: Discuss each requirement for MTG.
Emphasize those required by the regulations.
Slide 25 (graphic): Enlarged sample calibration
chart. Point out the depth (in inches), tank
capacity, and how to find the product volume.
Emphasize that the owner/operator should have
the calibration chart for his or her tank from the
tank's manufacturer.

Slide 26:  Discuss how MTG works.
Slide 27: Discuss the chart of weekly and
monthly standards for volume change.
                                                          Chapter Four, Page 9

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              Lecture Notes
                                          Instructional Aids
Tank
Capacity
faaU
Weekly   Monthly   Test
Change  Change  Duration
faat.)     taal.)     fhrs.i
Up to 550          10        5       36
55M ,000{64'x73")   9         4       44
1,000(48'X128")     12        6       58

If MTG is combined with TTT:
1,001 - 2,000       26        13      36
        2.   When MTG is appropriate

             a.    UST system characteristics

                  Only tanks of 1,000 gallons
                  or less can use MTG as the
                  only leak detection method
                  for the life of the tank.

                  Tanks between 1,001 and
                  2,000 gallons must combine
                  MTG with tank tightness
                  testing. This combined
                  method can be used only
                  for ten years following new
                  tank installation or upgrade
                  of existing USTs. Tank tight-
                  ness tests must  be per-
                  formed annually for existing,
                  non-upgraded USTs, and
                  every five years for up-
                  graded and new USTs.
                  (USTs that have not been
                  upgraded cannot use this
                  combined method after
                  December 1998.)

             -    Tanks larger than 2,000
                  gallons cannot use MTG.

                  MTG cannot be used for
                  piping.

             b.    Product characteristics

                  Not restricted to particular
                  fuel types.
                             Slide 28: Discuss tank size and the restrictions
                             that apply.
                             Slide 29: This method is not restricted to fuel
                             types. However, a heavier fuel, such as used oil,
                             will be easier to measure.  (Imagine using a dip
                             stick to measure alcohol vs. measuring used oil.
                             The alcohol level would be difficult to read due
                             to evaporation.)
                                                                      Chapter Four, Page 10

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 Lecture Notes
             Instructional Aids
     Works best with heavier
     fluids (such as used oil and
     diesel) because they don't
     evaporate easily, are less
     sensitive to temperature
     changes, and can be seen
     more easily on the gauge
     stick.

c.    Soil conditions

     Use is not restricted by soil
     type.

d.    Climatic factors

     Ambient (surrounding)
     temperature changes may
     affect volume of stored pro-
     duct due to expansion and
     contraction of liquid.  This is
     one of the  reasons the test
     must last so long.

     If temperature change is
     great, the testing period can
     be lengthened so that the
     beginning and ending
     gauge measurements can
     be taken at the same time of
     day.

     Because this method does
     not account for temperature
     change, false alarms may
     occur in areas of extreme
     temperature variation.

e.    Geologic conditions

     If the ground water is higher
     than product level in  a
     leaking tank, it can exert
     pressure that can hide a
     leak from MTG.

     Permanently high ground
     water may  render this
     method inappropriate.
Slide 30:  Mention that the testing period can be
extended so that the tests are conducted at the
same time of day. This may be important in
areas where the temperature varies greatly
between day and night.
Slide 31:  Once again, ground water may mask
a leak.
                                                          Chapter Four, Page 11

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           Lecture Notes
                                                   Instructional Aids
C.
3.   Considerations

          UST system must be
          removed from service at
          least 36 hours every week.

          Equipment costs are very
          low.

Secondary containment with
Interstitial monitoring

1.   How secondary containment with
     interstitial monitoring works

Secondary containment involves
placing a barrier between the tank and
its surrounding environment. The bar-
rier may fully or only partially enclose
the UST. Leaks are contained  in the
space between the tank and its
secondary barrier. In addition, inter-
stitial monitoring systems test for pres-
ence of released product in the space
(interstice) between the tank and its
outer containment barrier.

     a.    Secondary containment may
          include:

          Concrete vault;

          Double-walled tank;

          Tank with excavation liner;
          and
              Internal bladder.
                                           Slide 32: Tanks must be taken out of service for
                                           at least 36 hours a week.
                                           Answer any questions pertaining to MTG.
Slide 32A (graphic photo): Interstitial monitor-
ing.

Slide 33:  Discuss how secondary containment
provides a barrier between the tank and the
surrounding environment. The interstitial monitor
tests for leaks in the space between the tank
and the barrier.
Slide 34 (graphic):  Shows tanks within a con-
crete vault. They are on supports, as shown,
with or without backfill.  Notice the sump
installed for detecting leaks.

Slide 35 (graphic):  Shows double-walled tanks.

Slide 36 (graphic):  Shows a diagram of a tank
with a liner installed.

Slide 36A (photo): Excavation liner.

Slide 36B (photo): Spread out liner.

Slide 36C (photo): Tank and observation wells
installed.

Slide 36D (photo): Backfill.

Slide 36E (photo): Internal bladder.

Slide 36F (photo): Internal bladder installed in
tank.

Slide 36G (photo): Interstitial space monitor for
internal bladder.
                                                                    Chapter Four, Page 12

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 Lecture Notes
             Instructional Aids
b.   Fully enclosed systems
     include:

     Concrete vaults,

     Double-walled tanks, and

     Internal bladders.

c.   Partially enclosed systems
     may include:

     Excavation liners.

     In areas of heavy rainfall,
     liners should fully enclose
     the tank to prevent rainwater
     from sitting in the backfill
     and interfering with the mon-
     itoring equipment.

d.   Interstitial monitoring
     methods include:

     Electrical conductivity
     methods monitor changes in
     conductivity by  differentiat-
     ing between petroleum (non-
     polar) and water (polar).

     Pressure sensing methods
     apply either vacuum or pres-
     sure to the interstitial space.
     A leak is detected by chang-
     es in pressure.

     Liquid sensors detect the
     presence of a liquid by use
     of coated fibers or other
     materials that respond pre-
     ferentially to liquid in the
     tank. Alternatively, there
     may be a pressure switch at
     the bottom of the interstitial
     space.

     Hydrostatic sensors monitor
     changes in the level of liquid
     in the interstitial space.

     Manual detection methods
     use product-finding paste on
     a dipstick to find liquid pro-
     duct in the interstitial space.
Slide 37:  Discuss each monitoring method.
Which are most common in your State?
Slide 38 (graphic): Shows where sensors for
two types of interstitial monitoring are placed.
Mention that the system would normally use only
either vapor or liquid sensors, not both.
                                                            Chapter Four, Page 13

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      Lecture Notes
             Instructional Aids
          Vapor monitoring checks for
          presence of product fumes
          in the interstitial space.

2.   When secondary containment
     with interstitial monitoring is
     appropriate

     a.    UST system characteristics

          This method can be used
          for both tanks and piping.

              Containment system for
              piping involves placing
              liner underneath or
              around piping to
              establish interstitial
              space, assembling a
              pipe within a larger
              diameter pipe, and
              double-walled piping.

          Double-walled tanks are
          seldom larger than 20,000
          gallons.

              Larger tanks are very
              heavy and difficult to
              ship.

          Excavation liners may be
          used around any size tank.

          Secondary containment is
          impractical for existing tanks
          and piping, except when
          internal bladders are
          available for existing tanks.

              Installation for existing
              tanks and piping
              requires substantial
              retrofitting.

     b.    Product characteristics

          Use of this method is un-
          restricted for all fuel types.

     c.    Soil conditions

          Use of this method is not
          restricted by soil type.
Slide 39:  Discuss each point on the slide.
Slide 40:  Note that this is the only method that
can always be used for hazardous substances,
as long as interstitial monitoring is appropriate
for the stored substance. Other methods can be
used with hazardous substances if the manufac-
turer can demonstrate that the method is effec-
tive.  This course does not prepare the student
to determine if the other methods are
appropriate for specific hazardous substances.
                                                                Chapter Four, Page 14

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      Lecture Notes
             Instructional Aids
     d.    Climatic factors

          This method can be used in
          all climatic conditions. How-
          ever, in areas with heavy
          rainfall, a barrier system
          which fully encloses the tank
          should be used to prevent
          rain from interfering with the
          monitoring system. A tank
          liner that only partially
          encloses the tank may
          collect water, and therefore
          is not appropriate.

     e.    Geologic conditions

          Tanks located in  areas with
          high ground water should
          use a fully enclosed contain-
          ment system.

3.    Considerations

     a.    Installation of secondary
          containment using liners
          requires even more careful
          attention  by professional
          installers than other leak
          detection methods.

     b.    Containment barrier used
          must be compatible with
          product stored.

          Exposure to product should
          not result in deterioration of
          barrier, which would release
          product into the environ-
          ment.

          For standard petroleum
          products, such as gasoline
          and diesel fuel, most liners
          sold by reputable firms are
          compatible with product.

          For other products, nature of
          product and type of barrier
          must be considered to en-
          sure an appropriate match.
Slide 41:  Areas where there is high annual
rainfall or a high water table will need to install
fully enclosed containment systems to prevent
water from interfering with the monitoring
system.
Slides 42, 43, and 44: Discuss other points to
consider when using secondary containment
with interstitial monitoring. What are other con-
siderations or problems that you have
encountered?
                                                                Chapter Four, Page 15

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           Lecture Notes
             Instructional Aids
          c.   If a leak occurs, the barrier
              provides a degree of protec-
              tion for surrounding environ-
              ment against exposure.

              This aspect differentiates
              this method from others,
              which detect  leaks but do
              not contain them.

              Lower corrective action
              costs associated with this
              method than  with other leak
              detection methods.

D.   Ground-water monitoring

     1.    How ground-water monitoring
          works

     Ground-water monitoring detects free
     product in monitoring wells. The moni-
     toring wells extend from the ground
     surface to several feet below the low-
     est water table level. The leaked
     product travels through  the soil and
     reaches ground-water wells and
     detection equipment.

          a.   Monitoring wells

              Generally one to four wells
              per UST system will
              adequately detect leaks.

              Wells must be placed in, or
              near, backfill so that they
              can detect leaks rapidly.
              To intercept free product the
              well screen must extend
              from the bottom of well to
              the highest point of the
              water table surface.

              On-site staff must check
              wells at least monthly for
              presence of free product.
Slide 44A (graphic photo):  Introduction to
ground-water monitoring.
Slide 45:  Discuss structure of ground-water
monitoring wells and how ground-water moni-
toring works.
Slide 46 (graphic):  Shows components of a
typical ground-water monitoring well.

Note:  It may be beneficial to bring in sections of
screening and other well materials.

Slide 47 (graphic):  Shows placement of a mon-
itoring  well, and how it will detect free product.
Slide 48 (graphic):  Shows that the screen must
cover the entire range of ground-water
fluctuation.
                                                                    Chapter Four, Page 16

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 Lecture Notes
             Instructional Aids
b.    Manual devices for detecting
     free product

     Grab samplers (bailers or
     buckets) collect liquid
     samples for visual inspection
     or on-site electronic
     analysis.

     Chemical-sensitive pastes,
     attached to a weighted tape
     measure, are lowered into
     the well and change color
     when hydrocarbons are
     present.

     Manual devices must be
     used at least once a month.
     Additional measurements
     need to be taken during the
     month.

     Manual devices need to  be
     able to detect 1/8 inch of
     free product.

c.    Automatic devices for
     detecting free product

     These devices need to be
     able to detect 1/8 inch of
     free product.

     Differential float devices
     contain two floats:

         One float reacts only to
         liquids with density
         similar to water.

         One float responds
         only to liquids lighter
         than water.

         Different float levels will
         trigger  an alarm.

     Product soluble devices:

         These devices are
         coated with material
         that degrades when
         exposed to hydro-
         carbons.
Slide 49:  Discuss manual sample collection,
such as use of bailers, and automated systems.

Slide 50:  Bring in examples of bailers and
paste, if possible.

Slide 50A (photo): Person using bailer.

Slide SOB (photo):  Person using bailer.

Slide 50C (photo): Drop stick with paste.
Slide 51:
work.
Describe how these detection devices
Slide 52 (graphic):  Shows cross-section of
differential float devices.  Note that graphic illus-
trates a monitoring well contaminated by a con-
siderable amount of product.
Slide 53 (graphic):
soluble device.
         Cross-section of product-
                                                           Chapter Four, Page 17

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           Lecture Notes
                                                   Instructional Aids
2.
          Thermal conductivity
          devices:

              These devices measure
              heat loss when a
              floating probe contacts
              certain liquids.

          Electrical conductivity
          devices:

              These devices measure
              changes in electrical
              resistance that trigger
              alarms.

          Automatic monitoring
          devices must be operated at
          least once a month.

          Automatic monitoring
          devices are either per-
          manently installed or placed
          in the well during each test.

When ground-water monitoring is
appropriate

     a.    UST system characteristics

          This method can be used to
          detect leaks from tanks and
          piping.

          This method may be used
          on any size tank.  For larger
          systems, more wells are
          added.

          This method may be retro-
          fitted, but installer must be
          careful not to puncture tanks
          or piping.

     b.    Product characteristics

     ~    Product density must be
          lower than that of water.
          (Product must float on top of
          water.)
                                           Slide 54 (graphic):  Cross-section of thermal
                                           conductivity device.
                                           Slide 55:  Discuss these and other factors that
                                           could affect applicability.
                                           Slide 56:  Product characteristics.
                                                                     Chapter Four, Page 18

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 Lecture Notes
             Instructional Aids
     The product should not mix
     easily with water.  (If it
     mixes, no free product layer
     will form.)

     This method is most com-
     monly used for gasoline and
     diesel fuels. (Alcohols and
     water-soluble chemicals are
     not appropriate.)

c.    Soil conditions

     If this method is used alone,
     soil and backfill material
     between well and LIST must
     be coarse and permeable
     (for example, sand or gravel)
     to allow released product to
     travel to wells.

     Hydraulic conductivity of
     backfill material and soil
     between tank and moni-
     toring well should be  more
     than  0.01 cm/sec.

     If national codes are fol-
     lowed for installation,  the
     above requirements and
     conditions will have been
     met.

d.    Climatic factors

     Very low temperatures may
     interfere with some moni-
     toring devices.  Ice can
     freeze monitors and interfere
     with product-soluble
     devices.

e.    Geologic conditions

     Level of ground-water table

          If this method is used
          alone, ground water
          must not be more than
          20 feet below the
          surface.
Note:  Product must be a floater" vs. a 'sinker,'
i.e., must not mix readily with water. Method is
most commonly used with gasoline and diesel
fuels.
Slide 57:  Explain the terms 'porosity' and
•hydraulic conductivity."  (Review from Chapter
Three)

Slide 57A (photo):  Drilling.

Slide 57B (photo):  Taking a soil core sample.

Slide 57C (photo):  Workers installing backfill.
Slide 58:  Discuss climatic problems relating to
ground-water monitoring as they pertain to your
State (e.g., high annual rainfall, low rainfall or
extreme temperatures).
Slide 59:  Discuss these requirements.
                                                           Chapter Four, Page 19

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      Lecture Notes
             Instructional Aids
               Ideally, the ground
               water should be
               between 2 and 10 feet
               from the surface.

          Fluctuations in water table
          level

               If water level falls below
               or rises above the well
               screen, this method
               alone becomes insuffi-
               cient to detect released
               product.

          Gradient of ground-water
          flow

               If the gradient is steep,
               the product may by-
               pass the monitoring
               wells.  The most com-
               plete coverage would
               have wells installed on
               all sides of the site to
               intercept product and
               ensure release detec-
               tion.

          Fractures and cavities

               Because free product
               tends to flow through
               fractures and cavities in
               the soil, wells that do
               not intercept these
               fractures and cavities
               will not detect free
               product.

3.   Considerations

     a.    Site assessment is  required
          before installation. This
          involves:

          Identification of soil type,
          ground-water depth and flow
          direction, and general
          geology of site.
Mention that it is essential to know the water
table level and gradient in order to have an
effective ground-water monitoring program.
Note:  Describe liquid flowing down a steep hill
vs. a gentle hill. The steep grade will cause the
liquid to travel in a narrow path, vs. a gentle
slope where the liquid might spread out more.
Similarly, a steep gradient may mean that the
release may flow past the well without being
detected.
Slide 60 (graphic): This graphic shows how the
well can be installed in a seemingly good place,
but due to the geology, will still not detect a
release.
Slide 61:  Discuss these considerations, and
any others you may have.  Is ground-water
monitoring used frequently in your State? What
specific problems prevent the use of ground-
water monitoring?
                                                                Chapter Four, Page 20

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           Lecture Notes
             Instructional Aids
              Identification of evidence of
              previous leaks that would
              falsely indicate a current
              release.

         b.   Simple operation of
              detection devices.

              On-site staff must take
              samples at least once a
              month.

         c.   When installing monitoring
              wells, it is essential to avoid
              puncturing tanks or piping
              for UST or utility lines (such
              as gas, sewer, water, and
              electric).

E.   Vapor monitoring systems

     1.   How vapor monitoring works

     Vapor monitoring systems check for
     presence of product fumes in the soil
     or backfill around tank.  After a leaked
     material evaporates,  its vapors travel
     through porous soil,  and may be
     detected by vapor monitoring equip-
     ment located in monitoring wells.

         a.   This method is operated
              either automatically or
              manually.

              Automatic systems incor-
              porate a network of sensors
              that test for presence of
              vapors in monitoring wells.

              Manual monitoring systems
              collect air samples from
              wells surrounding tank to
              determine presence of
              vapors.
Review ground-water monitoring.

Hand out the ground-water monitoring exercise
from Appendix II.  Discuss as a group once stu-
dents have had the opportunity to work through
the problem.
Slide 62:  Describe how vapor monitoring
systems work; they monitor for presence of
vapor from product near the UST system.  Men-
tion both automatic and manual systems.
Slide 63 (graphic):  (This slide has been
removed.)
Slide 64 (graphic):  A schematic diagram of an
UST system with vapor monitoring.
Slide 65 (graphic):  A map view of an UST sys-
tem with vapor monitoring. Note location of the
three types of vapor wells: background, tank,
and product line vapor wells.
                                                                   Chapter Four, Page 21

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      Lecture Notes
             Instructional Aids
2.    When vapor monitoring is
     appropriate
     a.    UST system characteristics

          This method can be used
          for both tanks and piping.

          This method can be installed
          as part of new or existing
          tanks and piping.

     b.    Product characteristics

          Vapor monitoring must be
          used with products that
          vaporize readily.  For
          example, gasoline, diesel
          fuel, and aviation fuels are
          appropriate, but fuel oils
          No. 4 or No. 6 are not.

     c.    Soil conditions

          The backfill and soil around
          the tank must be porous
          enough to allow the vapors
          to reach the monitoring
          wells.

          For example, sand and
          gravel are porous materials.
          Clay is not porous and
          should not be used as
          backfill.

          Backfill and nearby soil must
          be clean and should not
          contain substances that will
          produce vapors.

          Previously contaminated soil
          may lead to false readings,
          indicating releases.

     d.    Climatic factors

          Temperature affects the
          volatility of released  product.
          Sensors may need to be
          adjusted for extreme
          temperatures.
Slide 65A (graphic photo):  Vapor monitoring
system.

Slide 65B (graphic photo):  Vapor monitor.

Slide 66:  Discuss applicability of vapor
monitoring.

Slide 66A (graphic photo):  Vapor monitoring
trends upon start-up.

Slide 66B (graphic photo):  Vapor monitoring
detecting a spill.

Slide 66C (graphic photo):  Soil Sentry data.

Slide 67:  Give examples of fuels that are most
appropriate for vapor monitoring due to their
high volatility (e.g., gasoline).
Slide 68:  Discuss how backfills can distort
results, such as previous soil contamination.
Soil type can affect how the vapor can travel.
Slide 69 (graphic):  This graph demonstrates
the effects of soil conditions on vapor con-
centrations at a vapor monitoring well.  The ver-
tical axis is gasoline in ppm, the hon'zontal axis
represents time in days. Note that the vapor
concentrations are much lower in wet sand or
clay vs. the dry backfill.  These are all readings
taken from the same release, at the same
distance from the source.
Slide 70:  Climate.
                                                                Chapter Four, Page 22

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                 Lecture Notes
          Instructional Aids
—      This method should not be used in areas
        with heavy annual rainfall or extremely
        moist climates.

—     The water fills spaces between the soil
       particles, preventing vapor from travelling
       through the soil.  Vapors may also dissolve
       in the mositure before reaching the
        monitors.

—     Heavy rains may fill monitoring wells with
       water and drown sensors, if not properly
       capped and sealed.

e.     Geologic conditions

—     This method should not be used in areas
       with high ground water because water
       interferes with vapor detection (as explained
       above).

3.     Considerations

a.     Manual monitoring systems require monthly
       time investment to obtain samples and have
       results analyzed.

—     The time required increases for each tank
       included in system.

—     Large sites require considerable time each
       month.

—     Samples are often sent offsite for analysis.

b.     Owners and operators of existing USTs that
       have not been upgraded should consider
       using spill and overfill protection when using
       vapor monitoring.
Slide 71: Discuss slide.
Slide 72: Discuss these and other consider-
ations that are appropriate for your area.
Hand out the vapor monitoring exercise from
Appendix II.  Discuss as a group once students
have had the opportunity to work through the
problem.
                                                   Slide 73:  (This slide has been removed.)
                                                                          Chapter Four, Page 23

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                Lecture Notes
           Instructional Aids
F. Statistical Inventory Reconciliation (SIR)

The five monthly monitoring methods described so
far were all identified in the Federal regulations that
became effective in December 1988. The
regulations provided, however, that other release
detection methods could be approved in the future if
those methods could meet EPA's performance
standards for release detection.  In June 1990, EPA
published a standard test procedure for an
additional release detection method that is known
as Statistical Inventory Reconciliation (SIR). SIR
methods must be evaluated using EPA's standard
test procedure or an equivalent procedure to prove
they can meet EPA's release detection performance
standards.

1. How SIR works

Statistical inventory reconciliation (SIR) analyzes
inventory, delivery, and dispensing data collected
over a period of time to determine whether or not a
tank system is leaking.

a.      Each operating day the operator measures
        the product level using a gauge stick or
        other tank level gauge.  A calibration chart
        specific to the tank is used to convert
        product level into product volume.

—      The operator also keeps complete records
        of all withdrawals from the LIST and of
        deliveries to the LIST.

—      After data have been collected for the
        period of time required by the SIR vendor,
        this information is provided to the SIR
        vendor.

b.      The SIR vendor uses sophisticated
        statistical software to conduct a
        computerized analysis of the data that can
        identify if the LIST is leaking.

c.      Every month, the SIR vendor reports the
        results of the analysis to the operator, who
        keeps monthly reports on file for at least 12
        months.
Slide 73A: Discuss basic SIR operation.
                                                                           Chapter Four, Page 23A

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                Lecture Notes
           Instructional Aids
d.      The Federal requirements for monthly
        release detection are-met-if the'SIR analysis*
        is performed every month, is capable of
        detecting release rates of at least 0.2 gallons
        per hour (with a probability of detection of
        0.95 and a probability of false alarm of 0.05),
        and the monthly results are available at the
        LIST facility. State and local  requirements
        can be more restrictive.

e.      Also, SIR can qualify as a tank tightness test
        if it meets the Federal requirements of
        detecting release rates of at least 0.1 gallons
        per hour with a probability of  detection of
        0.95 and a probability of false alarm of 0.05.
        (Tank tightness testing is  discussed in
        section III.B below.) State and local
-*.*»•:< smrequirementSiCan be-more restrictive.

2.      When SIR is appropriate

a.      UST system characteristics

—      SIR procedures apply to fueling sites where
        the required measurements can be taken
        every operating day. It is not appropriate for
        unattended facilities, unless the required
        data can be retrieved remotely.

—      SIR systems may be used on tanks up to the
        capacity for which an individual SIR system
        is evaluated.  SIR systems are generally not
     • <• • certified for use on tanks larger than 18,000
        gallons.

b.      Product characteristics

—      SIR is generally not restricted by product
        type.

 c.      Soil conditions

—      SIR is not  affected by soil type.

d.      Climatic factors

—      Changes in climate, especially temperature,
        affect the data used in SIR, so SIR vendors
        must take  climatic factors into consideration
        in their procedures.
 Slide 73B: Discuss Federal requirements, noting
•that tank tightness testing will be described in next
 section.
 Slide 73C: Discuss these characteristics.
 Slide 73D: Note that SIR vendors must be able
 to account for variables introduced by climatic
 factors and geologic conditions.
                                                                            Chapter Four, Page23B

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                Lecture Notes
           Instructional Aids
e.     Geologic conditions

—     Ground water around a tank may hide a
       hole or distort the data to be analyzed by
       temporarily reducing or preventing the
       product from leaving the tank. To detect a
       leak in this situation, the UST operator must
       check for water at least once a month.

3.     Considerations

—     SIR can be used for tank and piping
       systems.

—     SIR should not be confused with other
       release detection methods that also rely on
       periodic reconciliation of inventory,
       ^.withdrawal, or delivery data.  Unlike manual
       tank gauging and automatic tank  gauging
       systems (described earlier) or inventory
       control (described in the following section),
       SIR uses a sophisticated statistical analysis
       of data to detect releases.  This statistical
       analysis can only be done by competent
       vendors of SIR systems.

—     The procedures used by the  SIR  vendor
       must be evaluated against EPA's standard
       test procedures (or an equivalent protocol)
       to confirm that the procedures are capable
       of meeting the Federal regulatory
       requirements regarding the detection of
       minimum release rates and the probabilities
       of detection and false alarm.

—     Tank level and meter readings should be
       taken carefully at the same time each
       operating day, at  a time when no product is
       being delivered or dispensed. SIR does not
       require that the tank be out of service for
       extended periods.

—     Data can be transmitted to the SIR vendor
       on paper or by using computer modems or
       diskettes.

—     SIR can identify problems other than
       leaking systems,  such as miscalibrated
       meters, tilted tanks, and loss resulting from
       theft.
Slide 73E:  Emphasize that SIR should not be
confused with other inventory methods, because
SIR depends on extremely sophisticated statisti-
cal analysis that requires a competent SIR vendor
using software and computers effectively.
Slide 73F: Discuss these considerations.
                                                                           Chapter Four, Page 23C

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         Lecture Notes
Instructional Aids
SIR requires minimal investment of staff time
and equipment costs (usually involving a
gauge stick and pastes that help identify
product and water levels). The cost of
services provided by SIR vendors compares
favorably with the cost of other leak detection
methods.

State and local governments can place
restrictions on the use  of SIR  for compliance
purposes.
                                                                  Chapter Four, Page23D

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           Lecture Notes
             Instructional Aids
LEAK DETECTION METHOD: INVENTORY
CONTROL & TANK TIGHTNESS TESTING

Inventory control must be combined with
tank tightness testing to meet the leak
detection requirements.  This combined
method can  be used only during the first
ten years following the installation of a new
UST or the upgrade of an existing UST.
Existing USTs without upgrade cannot use
this combined method after December 1998.

A.   Inventory control

     1.    How inventory control works

     Inventory control is a daily accounting
     system in which records of input and
     output of a product are compared to
     the measured product volume in an
     UST.

              Inventory control is only
              acceptable as a leak detec-
              tion method when used with
              periodic tank tightness
              testing.

              Volume of product in the
              tank, deliveries, and sales
              are recorded daily.

              Each month the owner or
              operator balances accounts
              of deliveries and product
              sold from the tank with daily
              volume measurements.

              This method must be able to
              detect a monthly loss of 1.0
              percent of flowthrough plus
              130 gallons.

              If overage or shortage
              equals or exceeds 1.0 per-
              cent of the tank's flow-
              through volume plus 130
              gallons of product, the UST
              may be leaking.
Slide 74:  Discuss slide.
Slide 74A (graphic photo):  Inventory Control
with tank tightness testing.
Slide 75:  Explain that inventory control is a
daily accounting system (vs. manual tank
gauging which is performed weekly).
Leak is indicated if there is an overage or short-
age in tank volumes.  Shortages could be due to
leaks  and release into the environment; over-
ages could be the result of a hole into which
water is seeping.
                                                                   Chapter Four, Page 24

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 Lecture Notes
             Instructional Aids
a.    Daily tank gauging and
     reconciling

     Each morning and evening
     (or after each shift) product
     level is measured with a
     gauge stick marked to one-
     eighth of an inch.  This pro-
     cedure should be  conducted
     at regular intervals.

     A gauge stick is inserted
     vertically through the fill pipe
     until it touches the tank's
     bottom.

          Product-finding paste
          can be used  to high-
          light the level on the
          gauge stick.

     A calibration chart specific
     to the tank is used to con-
     vert product level into pro-
     duct volume. Similarly,
     water at the bottom of the
     tank is  measured and ac-
     counted for in the  recon-
     ciliation.

     Every day, product volume,
     withdrawals, and deliveries
     are recorded.

b.    Monthly reconciliation

     At least monthly, daily data
     on product volume, and the
     amounts of product de-
     livered to and withdrawn
     from the UST are reconciled.

     Daily overages and short-
     ages that fluctuate randomly
     around zero are common for
     USTs without a leak.
Slide 76:  Describe the method of record-
keeping.

Slide 76A (photo): Person using gauge to
measure tank volume.
Slide 77:  Mention that it is essential that gaug-
ing be performed accurately.
Slide 78 (graphic):  Part of a sample calibration
chart. Note that appropriate tank size column
must be used to convert measured depth in
inches into product volume in gallons.
Slide 79 (graphic):  Shows part of a monthly
reconciliation form.
                                                          Chapter Four, Page 25

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      Lecture Notes
                                              Instructional Aids
2.
     If monthly overage or short-
     age is greater than or equal
     to 1.0 percent of tank's flow-
     through volume plus 130
     gallons of product, the UST
     may be leaking.

         If this overage or short-
         age occurs over two
         consecutive  months,
         the owner  or operator
         must report results to
         local implementing
         agency as a  possible
         leak.

c.    Tank stock control

     Dispensing meters must be
     correctly calibrated to local
     weights and  measure stan-
     dards to ensure accuracy of
     inventory control.

     Product delivery volumes
     must be verified.

     Unaccounted for additions
     and withdrawals (such as
     spillage or thefts) must be
     included in the recon-
     ciliation.

When inventory control  is
appropriate

a.    UST system characteristics

     Any size tank is appropriate
     as long as inventory control
     can meet the performance
     standard of 1.0 percent of
     flow-through plus 130
     gallons.

     If the tank is not level you
     will need to create your own
     tank chart by adding incre-
     ments of product and
     reading the corresponding
     level.
                                      Slide 80: Review monthly procedures.
                                      Slide 81: It is very important to recognize and
                                      account for inaccurate meters and dispensers in
                                      the inventory.
                                      Slide 82 (graphic): Shows a flow chart of the
                                      inventory control procedure. Talk through this.
                                      Slide 83: Explain this performance standard.
                                      Slide 83A (photo):
                                      if tank is level.
Instrument used to measure
                                                               Chapter Four, Page 26

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 Lecture Notes
             Instructional Aids
b.    Product characteristics

     This method is effective for
     gasoline and diesel fuel and
     products that have similar
     viscosities and thermal
     properties.

     If other products are stored,
     owner/operator should en-
     sure that this method can be
     used satisfactorily with those
     substances.

c.    Soil conditions

     Use is not restricted by soil
     type.

d.    Climatic factors

     The ambient temperature
     should be noted when
     taking gauge readings.
     Inventory control is most
     accurate when performed at
     same time each day.

     The temperature difference
     between newly-delivered
     product and product in tank
     limits accuracy of inventory
     control.

     Temperature increase or
     decrease causes expansion
     or contraction of product,
     and may mask or imitate a
     leak.

e.    Geologic conditions

     High ground water may
     interfere with measurement.
     If water level fluctuates,
     testing will be able to catch
     leak only during low water
     levels.

     Inventory control may be
     inappropriate for areas with
     permanent high ground
     water.
Slide 84:  Discuss slide.
Slide 85:  Discuss climate vulnerability as it ap-
plies to your State.
Slide 86:  Ground water poses the problem of
masking a leak.
                                                           Chapter Four, Page 27

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      Lecture Notes
             Instructional Aids
              If water level is high
              enough to cover a hole
              in the leaking tank, it
              can counteract outward
              pressure of stored
              product and mask a
              leak.

          A monthly measurement
          using a gauge covered with
          water-finding paste must be
          taken to identify any water at
          bottom of tank.

              If water level in the tank
              is over one-half inch,
              water must be
              removed.

              Water volume should
              be accounted for in the
              reconciliation.

3.   Considerations

     a.    Inventory control must be
          combined with periodic tank
          tightness tests. This com-
          bined method can be used
          for only ten years following
          installation of new USTs or
          upgrade of existing USTs.

     b.    This method requires:

          Daily product gauging;

          Calibration of meters; and

          Recording and monthly
          calculation of overage or
          shortage compared to total
          flow-through.

     c.    Staff time is required every
          day, but doesn't require
          much time.  Also, many
          facilities already practice
          inventory control.

     d.    Small leaks may go un-
          detected for a long period.
Mention this monthly requirement to determine
water level in the tank.
Slide 87:  Discuss these considerations for
inventory control.

Slide 88:  (This slide has been removed.)
                                                               Chapter Four, Page 28

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           Lecture Notes
             Instructional Aids
         e.   This method is applicable
              only to metered storage
              tanks.

         f.    Deliveries must be made
              through a drop tube that
              extends to within one foot of
              the tank's bottom.

         g.   Inventory control results can
              be affected by variation in
              temperature, theft, tank tilt,
              and discrepancies in meter
              calibration, the tank calibra-
              tion chart used, and delivery
              overages or shortages.

B.   Tank tightness testing

     Tank tightness testing identifies leaks
     in closed tank systems and must be
     performed annually in existing non-
     upgraded tanks and every five years in
     new or upgraded tanks.  Tank tight-
     ness testing must be performed along
     with inventory control, but this com-
     bined method can be used only during
     the first ten years following installation
     of a new UST or upgrade of an exist-
     ing UST. Neither method alone is an
     acceptable method of leak detection.

     The two types of tank tightness testing
     are volumetric and  non-volumetric
     testing.

     1.   How tank tightness testing works

         a.   Volumetric testing

              Changes in product level or
              volume in tank over several
              hours are measured
              precisely (in milliliters or
              thousandths of an inch).

              Changes in product temper-
              ature must also be meas-
              ured in some methods to
              account for temperature-
              induced changes in product
              volume.
Slide 89:  This slide discusses possible sources
of error in interpreting inventory control results.

Slide 90:  (This slide has been removed.)
Slide 91:  Tank tightness testing OTT) identifies
leaks in a closed system. There are both volu-
metric and non-volumetric tests.
Slide 92:  Discuss volumetric testing.

Slide 93 (graphic):  Discuss level and tempera-
ture gauges.

Product level is measured over a period of
several hours.

Slide 93A (graphic photo):  Petrotite.

Slide 93B (photo): Test site overview (petrotite).

Slide 93C (photo): Standpipe (petrotite).

Slide 93D (photo): Petrotite van and stand
pipe.
                                                                    Chapter Four, Page 29

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  Lecture Notes
             Instructional Aids
     Tests are conducted either
     on partially filled or overfilled
     tanks.

          In a partially filled tank,
          test is conducted with
          the product level below
          the top of the tank.
          Because product level
          changes occur in a
          large surface area,
          small changes in
          volume create very
          small changes in pro-
          duct level.

          In an overfilled tank
          test, the tank is filled
          until the product level
          reaches the fill tube or
          a standpipe located
          above grade.  Because
          product level changes
          occur in a small sur-
          face area, small chang-
          es in volume cause
          large changes in level.

     A net decrease in  product
     volume during testing
     indicates a leak.

b.   Non-volumetric testing

-    Instead of monitoring for
     changes in product level or
     volume, these methods look
     for some other evidence of a
     leaking tank.

     Acoustic testing methods
     use equipment that 'listens'
     for the sound of air bubbling
     through a hole or the sound
     of turbulent product at a
     hole. This method may not
     work well where the water
     table is high  or where the
     tank sits in mud.
Slide 93E (photo):  Reading results.

Slide 93F (photo):  Sample chart.

Slide 94 (graphic):  (This slide has been
removed.)

Slide 95 (graphic):  Partially filled and overfilled
tanks.
Slide 96:  There are several methods of non-
volumetric testing.  An 'acoustic' test detects
small bubbles that may indicate a leak.
                                                          Chapter Four, Page 30

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 Lecture Notes
             Instructional Aids
     Tracer methods add an
     easily detected liquid or
     vapor to the tank.  The
     backfill surrounding the tank
     is monitored to see if the
     tracer escapes.

c.    General details

     The test equipment is tem-
     porarily installed in the tank,
     usually through  the fill pipe.

     The tank must be taken out
     of service for duration of
     test.  Tests may last 6-12
     hours.

     Test must  be able to detect
     loss of 0.1  gallon per hour
     from any portion of tank that
     routinely contains product.

     Some methods require that
     product in the tank be at a
     certain level before testing.

         The owner or operator
         may have to add pro-
         duct from another tank
         on-site or purchase
         additional product.

     If new product is added to
     tank to prepare  it for testing,
     the test cannot be con-
     ducted until the temperature
     of the tank contents has
     stabilized.

     Tank deformation and tem-
     perature in tank must be al-
     lowed to stabilize.

     If product is added during
     the test to make fine
     adjustments in tank volume,
     tank contents must again be
     allowed to stabilize before
     the test can continue.
Slide 96A (photo):  Tanks holding a tracer gas,
helium.
Slides 97 and 98 (graphics): These graphics of
tanks show how changes in product tempera-
ture, and structural deformation of the tank can
be mistaken for a leak.  These graphics help to
explain why  a wait period is suggested before
tests are conducted.
                                                           Chapter Four, Page 31

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      Lecture Notes
             Instructional Aids
     d.   Application of test

         A testing company performs
         tests.

     -   Some methods require
         tester to make measure-
         ments and calculations by
         hand.

         Some methods are highly
         automated and have com-
         puterized measurements
         and analysis.

2.    When tank tightness testing is
     appropriate

     a.   UST system characteristics

         Tightness tests can be used
         for both tanks and piping.

         Tightness testing is primarily
         used for tanks smaller than
         15,000 gallons.

         If tank tightness testing is
         used for larger tanks, the
         owner/operator should make
         sure that the manufacturer
         or vendor has proof that it
         will meet the performance
         standard when  used  on
         larger tanks.

         With automated tank tight-
         ness test methods, up to
         four tanks may  be tested at
         one time.

     b.   Product characteristics

     -   To date this method has
         been used primarily in tanks
         containing gasoline, diesel,
         and light heating oils.

         If other products are  stored,
         the owner or operator
         should ensure that this
         method can be used satis-
         factorily with those
         substances.
Note that tests are conducted by private com-
panies, not the owner or operator. Testing is
conducted annually or every five years
depending on whether the tank is unimproved or
has been upgraded or is new. The tester
temporarily installs equipment into the tanks.
Slide 99:  Discuss applicability.
                                                               Chapter Four, Page 32

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 Lecture Notes
             Instructional Aids
c.    Soil conditions

     In volumetric testing, if the
     backfill allows the tank to
     'bulge,' one may have to
     wait longer for tank to
     stabilize between filling the
     tank and beginning the test.

d.    Climatic factors

     In volumetric testing, wait at
     least six hours between
     delivery and testing to
     stabilize temperature differ-
     ences between added prod-
     uct and product already in
     tank. The wait time  may
     vary due to climate.

         Temperature differen-
         ces could cause dif-
         ferences in densities,
         which would result in
         different product
         capacitances.

         Very cold weather will
         cool product in fill pipe.
         This cooler product
         drops into the tank,
         cooling the product
         below the fill pipe, and
         creates erroneous
         readings.

e.    Geologic conditions

     Ground-water level must be
     determined before this
     method is applied.

     Presence of ground water
     may mask an actual leak or
     slow the  rate at which   •
     product is leaking.

     If water table is higher than
     location of hole in leaking
     tank, ground water exerts
     pressure on hole.
Slide 100:  The wait time may have to be
lengthened if the backfill is such that it allows
the tank to bulge.
The presence of ground water is particularly
important with this method due to the infrequent
testing that takes place. If a leak is masked, it is
possible that it may  not be detected for one or
five years when the  next test is conducted.
                                                           Chapter Four, Page 33

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      Lecture Notes
             Instructional Aids
          Water counteracts pressure
          exerted on hole by fluid in
          tank. This condition may
          mask or slow a leak.

          This is particularly important
          with tank tightness testing
          due to the length of time
          between tests.  A false read-
          ing may not be caught until
          the next test is performed.

          The best methods can com-
          pensate for high ground-
          water levels if these levels
          are known prior to tank
          testing.

3.    Considerations

     a.    Tightness tests must be
          used with inventory control
          method. This combined
          method can only be used
          for ten years following new
          UST installation or upgrade
          of existing USTs.

     b.    Tank must be taken out of
          service during a test.

     c.    Access problems may make
          it difficult to set up test
          equipment. Tester should
          be aware  of layout of site
          beforehand.

     d.    Permanent installation of
          equipment is unnecessary.

     e.    Many different commercial
          methods are available.

     f.    It is vital that tester follows
          proper testing methods.
Slide 101:
limitations.
Discuss these considerations and
Slide 102:  Review of Chapter Four. Answer
questions.
                                                               Chapter Four, Page 34

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                                    CHAPTER FIVE
                 LEAK DETECTION METHODS FOR UST PIPING
How can you assist the owner or operator to meet the leak detection requirements for piping?
This chapter presents detailed information about the two types of UST piping systems, pressurized
and suction, and the requirements for piping monitoring and leak detection methods. This chapter
covers types of line devices, line testing methods, and monthly monitoring methods.
               Lecture Notes
            Instructional Aids
I.    UST PIPING

     The majority of UST leaks occur in the
     piping system. Two varieties of piping sys-
     tems for product delivery are pressurized
     piping and suction piping.

     A.   Pressurized piping systems

         1.   A pump at the bottom of the tank
              pushes product through the
              delivery piping to the dispenser at
              positive pressure, usually around
              28 to 32 pounds per square inch
              (psi).

         2.   Very large releases can occur
              quickly because pumps continue
              to operate when piping is broken
              and force product through the
              hole or break.

         3.   These systems are usually
              chosen for high volume sites
              because they deliver product
              quickly.

     B.   Suction piping systems

         1.   A positive displacement pump, at
              or near the point of end use,
              reduces the pressure at the dis-
              pensing unit, and atmospheric
              pressure pushes the product
              through delivery lines.
Slide 1: Chapter Five slides.

Slide 2: Introduce the chapter on leak detection
methods for piping.

Slide 2A (photo):  Leaking pipe.

Slide 3: There are two varieties of piping. The
first is pressurized piping.

Explain that with pressurized piping releases can
occur very quickly, posing a threat to the
environment.
Slide 4: The second variety of piping is suction
piping.

Slide 4A (photo):  Suction pump dispensers.

Slide 4B (photo):  Suction pump dispensers.
                                                                        Chapter Five, Page 1

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      Lecture Notes
             Instructional Aids
2.   When the pump is shut off or a
     leak in the lines occurs, suction is
     interrupted, and product flows
     back through the piping toward
     the tank.

          Some product remains con-
          tained in the lines by one or
          more check valves within the
          pipe system.

          At the point of a line failure,
          some product can not drain
          back into the tank  and es-
          capes into the environment.

3.   Two general types of suction
     systems exist:

          In the 'European' system,
          the location of the check
          valve is immediately below
          the pump.  Also, the slope
          of the piping will allow pro-
          duct in the piping to drain
          back into the tank when
          suction is released.

          In the 'American' system,
          the check valve is located at
          the top of the tank (angle
          check) or at the bottom of
          the suction line (foot valve).

     Both systems are used in the
     United States.

4.   Suction piping systems  deliver
     product slowly, so they are only
     used where speed of delivery is
     not a factor. These systems also
     require that the dispenser and
     tank are near each other.
Explain that when the pump is shut off, the suc-
tion is interrupted.  If there is a leak, the product
will flow back toward the tank. The volume of
the release is much less for suction piping than
for pressurized piping because no pressure
forces product from the lines.
Slide 4C (graphic photo): Suction piping.
Mention the 'European" and 'American" systems.
Slide 5 (graphic): This diagram shows the
differences between the "American" and
"European" systems.  Both are used in the
United States.
Discuss when suction piping is used.  Limitations
of this system are the slow delivery rate, and the
short distance allowed between the tank and the
dispenser.
                                                                Chapter Five, Page 2

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               Lecture Notes
             Instructional Aids
II.   LEAK DETECTION FOR UST PIPING

     Federal regulations require that all UST
     piping systems that routinely contain pro-
     duct be tested for leaks. This may or may
     not include the vent lines, depending on the
     State requirements. Depending on the test
     method, piping may be tested separately or
     in conjunction with the tank.

     A.   Deadlines

         1.   Pressurized piping

*             -    New piping must comply
                   with UST leak detection
                   requirements when
                   installed.

«             -    Existing  piping  must comply
                   with UST leak detection
                   requirements by December
                   1990.

         2.   Suction piping

                   Leak detection  is not
                   required for either  new or
                   existing piping of the
                   "European" type described
                   earlier.

                   Other "American" suction
                   piping types need  to meet
                   the following deadlines.

                       New piping must
                       comply with UST leak
                       detection requirements
                       when Installed.

                       Existing piping must
                       comply with UST leak
                       detection requirements
                       according to the
                       following timetable:
Slide 6:  Introduce this section on deadlines and
requirements for leak detection.

Note:  Much of the information is the same for
tanks and piping.  You may not wish to repeat
those parts of this section that are redundant
with earlier material.
Slide 7:  Discuss regulations.  You may want to
repeat that 'new piping" refers to piping installed
after December 1988.
Slide 8:  Discuss suction piping deadlines,
emphasizing difference between "American" and
"European" style systems and their differing
compliance requirements.
                                                                         Chapter Five, Page 3

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           Lecture Notes
                                     Instructional Aids
  Installation     Must Comply
    Date	By	
  Before 1965
  1965-1969
  1970-1974
  1975-1979
  19SO-1988
December 1989
December 1990
December 1992
December 1993
  * Or If Installation date Is unknown.
B.   Requirements

     1.   Pressurized piping (new and
         existing)

              Each pressurized piping run
              must have an automatic line
              teak detector 01D).

              Pressurized piping must also
              have one of the following:

                  Monthly ground-water
                  monitoring; or

                  Monthly vapor monitor-
                  ing; or

                  Monthly interstitial mon-
                  itoring; or monthly SIR;

                  Annual tightness test

     2.   Suction piping

              No leak detection is required
              if the suction piping is
              designed with:

                  Enough slope so that
                  the product in the pipe
                  can drain back into the
                  tank when suction is
                  released; and

                  Only one check valve,
                  which is as close as
                  possible beneath the
                  pump in the dispensing
                  unit.
                                          Slide 9: Review chart.
                        Slide 10 (graphic): Pressurized piping system.
                        Note piping extending to bottom of tank.

                        Slide 11: Requirements for pressurized piping.
                        Slide 12: Discuss the leak detection
                        requirements for suction piping. Note that the
                        requirements are for systems that do not meet
                        the design requirements for exemption from leak
                        detection.
                                                                    Chapter Five, Page 4

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                Lecture Notes
           Instructional Aids
—    If a suction line does not meet all of these
      design criteria, one of the following leak
      detection methods must be used:

—    A line tightness test at least every three years;
      or

—    Monthly vapor monitoring; or

—    Monthly SIR;

—    Monthly ground-water monitoring; or

—    Monthly interstitial monitoring.

C.    Methods

1.     Automatic line leak detectors

—    Two types are currently available:

      - Automatic flow restrictor; and

      - Automatic shutoff device.

2.     Line tightness testing methods

—    Two general approaches are currently used:

      - Direct volumetric testing; and

      - Indirect tightness testing.

3.     Monthly monitoring methods

—    Four types exist:

      - Interstitial monitoring;

      - Ground-water monitoring;

      - SIR monitoring; and

      - Vapor monitoring.
Slide 13:  Introduce the acceptable methods
of leak detection or piping. Each method will
be discussed later in this chapter.
Sllde14: Leak detection methods.
                                                                            Chapter Five, Page 5

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                Lecture Notes
          Instructional Aids
D.     Requirements for PD/PFA

1.      Line tightness testing and automatic line leak
       detectors must be capable of detecting the
       leak rate or quantity specified for that method
       with a probability of detection (PD) of 0.95 and
       a probability of false alarm (PFA) of 0.05.

       There are two PD/PFA compliance deadlines:

—    By December 1990, tightness testing for
       piping must meet PD/PFA requirements;

—     By September 1991, automatic line leak
       detectors must meet PD/PFA requirements.

       However, methods permanently installed
       before the applicable compliance deadline are
       not required to meet the PD/PFA
       requirements.

E.      Standard test procedures

       As discussed earlier in Chapter Four, Section
       I.D., EPA has developed standard test
       procedures (also known as protocols) that
       enable manufacturers of release detection
       methods and third-party evaluators of those
       methods to demonstrate that the methods can
       meet the Federal release detection
       requirements.  EPA published standard test
       procedures for evaluating pipeline  leak
       detection systems in September 1990.
Slide 15: Discuss PD/PFA "95 and 5"
requirements.
                                                                         Chapter Five, Page 6

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                Lecture Notes
             Instructional Aids
III.   AUTOMATIC LINE LEAK DETECTORS

     A.  Automatic flow restrictors

         1.   How automatic flow restrictors
              work

                   Restrictors, located at the
                   pumps, monitor the line
                   pressure and restrict flow if
                   a possible leak is indicated.

                   When pressure in the pump
                   delivery system drops below
                   a preset threshold, common-
                   ly 1 to 2 psi, a test is auto-
                   matically performed.

                   During the test product flows
                   through line at 1.5 to 3
                   gal/h.

                   Line leak detectors must
                   detect 3 gal/h release at 10
                   psi pressure, within 1 hour.

                   Leaks greater than 3 gal/h
                   are indicated if more than 2
                   seconds are required to fully
                   pressurize the line.

                   If test does not indicate a
                   leak, normal flow is
                   resumed.

                   Restrictors do not shut  the
                   system off entirely, but  limit
                   product flow to 3 gal/h.

         2.   When automatic flow restrictors
              are appropriate

                   This method is used  only in
                   pressurized piping.

                   Most gas station USTs  al-
                   ready have automatic flow
                   restrictors (Red Jackets).
Slide 16:  Describe how automatic flow restric-
tors work and how they are set up. Discuss the
devices that are particularly common in your
State.

Slide 17:  Continue the discussion of automatic
flow restrictors.
Slide 18:  Discuss when automatic flow restric-
tors are appropriate.
Slide 18A (photo):  Red Jacket.
                                                                           Chapter Five, Page 7

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           Lecture Notes
             Instructional Aids
     3.    Considerations

              This method causes a slight
              lag in product delivery even
              when there is no leak.

              At high altitudes or high
              temperatures, vapors are
              more likely to form in piping.
              This increases the amount
              of time required for product
              to reach operating pressure
              and may falsely indicate a
              leak.

                   If additional time is
                   spent pressurizing the
                   line, vapors will usually
                   be reabsorbed into the
                   liquid.

              On-site staff may tamper
              with system to avoid delays
              in product delivery.

              Requires little owner or
              operator involvement.

              Tests can not be run while
              dispensers are in use.
              About five minutes between
              dispensings at the UST are
              needed for accurate testing.

              Typical time between dis-
              pensings should be con-
              sidered when selecting a
              method of piping leak
              detection.

B.   Automatic flow shutoff devices

     1.    How automatic flow shutoff
          devices work

          There are two different types of
          automatic flow shutoff devices:
          one system monitors for an
          increase in line pressure; the
          other monitors for a decrease in
          line pressure.
Slide 19:  Discuss these and other factors that
may need to be considered before using
automatic flow restrictors.
Slide 20:  There are two types of automatic flow
shutoff devices that will be discussed:  pressure
increase monitors and pressure decrease
monitors.
                                                                      Chapter Five, Page 8

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 Lecture Notes
             Instructional Aids
a.    Pressure increase monitor

     The normal rate of
     pressurization in pipes is
     calculated when the testing
     system is set up.

     When the pump is activated,
     the rate of increase in line
     pressure is measured.

     It will take  longer than usual
     for the piping to become
     fully pressurized if there is a
     leak.

     If pressure does not rise
     quickly enough, the system
     automatically shuts down.

     The level of automation
     varies from system to
     system.

     Automatic  flow shutoff
     systems are permanently
     installed.

b.    Pressure decrease monitor

     System monitors line pres-
     sure over several minutes
     when  dispenser is not in
     use.

     If constant pressure can not
     be maintained or if pressure
     decreases more quickly than
     its normal  rate, a leak is
     indicated, and the pump is
     shut down.

     Generally,  more than one
     test which indicates a leak is
     required before system
     shuts  down.

     The level of automation
     varies from system to
     system.

     Such systems are
     permanently installed.
Slide 21:  In this method the amount of time it
takes to fully pressurize a line is measured.
Automatic shutoff occurs when the length of time
for full pressurization is longer than usual,
indicating a possible leak.
Slide 22:  This method measures decreasing
pressure in the lines over a period of time when
the lines are inactive. The inability to maintain
normal pressure may indicate a leak.
                                                            Chapter Five, Page 9

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      Lecture Notes
             Instructional Aids
2.   When automatic flow shutoff
     devices are appropriate

          This method is used for
          pressurized piping only.

          Typical time between
          dispensings should be con-
          sidered when selecting a
          method of piping leak
          detection.

3.   Considerations

          Flow shutoff devices are
          subject to tampering if they
          are not locked or tamper-
          proofed in some way.

          As with flow restrictors, tests
          cannot be run while
          dispensers are in use.  At a
          minimum, about five  minutes
          between dispensing  at the
          UST are needed for
          accurate testing.

              A longer interval
              between dispensings
              (up to one hour) is
              necessary to detect
              small leaks.

          Automatic flow shutoff
          devices provide nearly con-
          tinuous leak detection and
          require little time from staff.
Slide 23:  Discuss slide. Mention when the
devices are appropriate, and that they allow for
only minimum product loss.
Slide 24:  Discuss these and other factors that
should be considered when using automatic flow
shutoff devices.
                                                               Chapter Five, Page 10

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               Lecture Notes
             Instructional Aids
IV.   LINE TIGHTNESS TESTS

     A.   Direct volumetric line tightness test
         1.   How direct volumetric line
              tightness tests work

                   The line is isolated from the
                   tank, and is tested for its
                   ability to maintain pressure.

                        A  pressure loss
                        indicates a potential
                        leak.

                        The test must be able
                        to detect a leak of 0.1
                        gal/hat 1.5 times the
                        normal line operating
                        pressure.

                   A hand pump or a dispenser
                   and submerged pump is
                   used to pressurize the
                   piping leading back to the
                   tank.

                   The amount of volume lost is
                   determined in one of several
                   ways:

                        If pressure decreases
                        in the piping system,
                        product is added to
                        return pressure to
                        original test level.  The
                        leak rate is estimated
                        by measuring the
                        amount of product
                        added.

                        The volume of product
                        lost over time is
                        observed in an above-
                        ground tube that is
                        connected to pressur-
                        ized piping.
Slide 25:  There are two line tightness testing
methods - direct volume and an indirect line
tightness test. Each method will be discussed in
this chapter.

Slide 26:  Describe how a volumetric line
tightness test is conducted.  Describe the
methods that are common in your State.
The piping between the tank and dispenser is
pressurized. The ability to maintain pressure is
measured in several ways. If a predetermined
volume is lost, a leak in the piping is indicated.
Mention that few of these devices are currently
available.
Slide 26A (photo):  Line tightness testing equip-
ment.

Slide 26B (photo):  Line tightness testing equip-
ment.

Slide 26C (photo):  Line tightness testing equip-
ment.
                                                                         Chapter Five, Page 11

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      Lecture Notes
             Instructional Aids
              A pressure gauge on
              the hand pump, or
              temporarily installed on
              the dispenser, can be
              used to indicate pres-
              sure change, which is
              converted to a leak
              rate.

          If a 0.1 gal/h per hour leak
          rate is found, a leak is
          indicated.

2.    When the direct volumetric line
     tightness test is appropriate

          This method can  be per-
          formed alone or in con-
          junction with other
          monitoring methods.

          With certain variations on
          tests, line tightness testing
          may be performed on both
          pressurized and suction
          systems.

3.    Considerations

          The line must be shut down
          for several hours for the test.

          This method requires no
          permanent equipment and
          can be performed along with
          tank tightness testing.

          Test needs to be performed
          only once every three years
          for suction piping. Line
          tightness testing can be
          used as the only method of
          line leak detection for suc-
          tion piping.

          There are generally more
          problems with line tightness
          testing than with tank
          tightness testing.  These
          problems are difficult to
          resolve due to poor fittings
          and gaskets, vapor pockets,
          bad check valves, etc.
Slide 27:  Can be used in conjunction with tank
tightness testing.
Slide 28:  Discuss these and other consider-
ations as they apply to your State.
                                                                Chapter Five, Page 12

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           Lecture Notes
             Instructional Aids
B.   Indirect line tightness test

     1.    How the indirect line tightness
          test works

          a.   In an indirect line tightness
              test, piping is tested as a
              part of a full tank system
              test.  Fluid loss over time in
              a closed tank and piping
              system is examined to deter-
              mine presence of a leak.
              Procedures are the same as
              for tank tightness test with
              the following additions:

              Overfill method must be
              used, so that piping as well
              as tank is full of product.

              If test indicates a leak, tank
              is tested alone.

              If no leak is found in tank,
              piping is assumed to be
              leaking.

              If tank is leaking, separate
              test of piping must be
              conducted.

     2.    When the indirect line tightness
          test is appropriate

              This method must be done
              in conjunction with tank
              testing; tanks and piping
              might be on different test
              schedules, making an
              indirect test impractical.

              With certain variations on
              tests, line tightness testing
              may be performed on both
              pressurized and suction
              systems.

              If low pressure is put on
              piping, it is necessary to
              detect very small leaks to
              pass the pressure piping 0.1
              gal/h test requirement.
Slide 29:  This method tests piping and the tank
as one system. If a leak is suspected, then a
systematic method of locating the leak is used,
testing each system part until the leak is
isolated.
Discuss this procedure.
Slide 30:  This method must be done along with
tank testing, and can be used on both pressur-
ized and suction piping.
                                                                      Chapter Five, Page 13

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      Lecture Notes
             Instructional Aids
3.    Considerations
         This method must be per-
         formed as part of tank test;
         therefore, UST system must
         be shut down for at least
         several hours.

         Requires no permanent
         equipment,  and can con-
         veniently be performed
         along with tank tightness
         testing.

         Test must be performed only
         once every three years for
         suction piping. Line tight-
         ness testing can be used as
         the only method of line leak
         detection for suction piping.

         There are generally more
         problems with line tightness
         testing than with tank
         tightness testing. These
         problems  are difficult to
         resolve and are due to poor
         finings and gaskets, vapor
         pockets, bad check valves,
         etc.

         Indirect tests can only show
         that the entire UST system is
         leaking. Tanks and piping
         will have to  be tested
         separately to identify the
         source of the leak.
Slide 31:  Discuss these considerations for in-
direct line tightness tests.
                                                                Chapter Five, Page 14

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                Lecture Notes
             Instructional Aids
V.   MONTHLY MONITORING METHODS

     A.   Secondary containment with
          Interstitial monitoring

          Methods, applications, and con-
          siderations of interstitial monitoring
          with secondary containment for piping
          systems are similar to those for tanks.

          1.    How interstitial monitoring works

               a.    Trench liners

                    Backfill and piping are
                    placed in a lined trench.

                    The trench should be sloped
                    away from the tank
                    excavation to differentiate
                    between tank leaks and
                    piping leaks.

                    An  interstitial monitor is
                    placed between piping and
                    the trench liner.

               b.    Double-walled piping

                    Piping that carries the pro-
                    duct is contained within a
                    larger outer pipe.

                    The outer pipe usually
                    drains to a sump that can
                    be  monitored for leaks.
                    Other methods use an
                    interstitial monitor placed
                    between inner and outer
                    piping.

          2.    When secondary containment
               with interstitial monitoring is
               appropriate

               a.    UST system characteristics

                    Can be used for both tanks
                    and piping.
Slide 32:  Discuss the use of interstitial
monitoring with piping.  It is very similar to that
used with tank systems; however, some differen-
ces will be discussed.
Slide 33:  Discuss trench liners.
Note that the system can be arranged such that
leaks in piping and tanks can be differentiated.
Slide 34:  Discuss double-walled piping.
The same applications of tank interstitial
monitoring apply to piping.  There are few
restrictions.

Slide 35:  Discuss when secondary containment
is appropriate.
                                                                          Chapter Five, Page 15

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      Lecture Notes
             Instructional Aids
          Secondary containment is
          impractical for existing
          piping, because it involves
          either excavating all piping
          runs and installing trench
          liners, or replacing existing
          piping with double-walled
          piping.
    i
    »b.    Product characteristics

          This method can be used
          for all types of fuels.

     c.    Soil conditions

          Use is not restricted by soil
          type.

     d.    Climatic factors

          This method can be used in
          all climatic conditions;
          however, in areas with heavy
          rainfall, a fully enclosed
          containment system should
          be used to prevent rain from
          interfering with monitoring
          system.

     e.    Geologic conditions

          In areas with high ground
          water, a fully-enclosed con-
          tainment system should be
          used to prevent ground
          water from interfering with
          the monitoring devices.

3.   Considerations

          Correct installation of trench
          liners is essential because
          piping trenches are narrow
          and long. To cover these
          areas requires piecing
          together small pieces of
          liner.  Trained and
          experienced professionals
          can minimize the number of
          seams in the liner and en-
          sure correct installation.
Slide 36:  This method can be used for all fuel
types.
Slide 37:  Discuss climatic and geologic
considerations.
Slide 38:  Discuss these considerations and any
others that apply to your State.

Installing liners in trenches can be very difficult
due to the number of seams required to line a
piping system.
                                                                 Chapter Five, Page 16

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           Lecture Notes
             Instructional Aids
              Proper installation of double-
              walled piping is also very
              important, and requires a
              professional.

              Piping monitoring can often
              be integrated with the tank
              monitoring system.

              This is the only leak detec-
              tion method that prevents
              product from entering the
              environment, thus reducing
              potential for cleanup costs.

B.   Ground-water monitoring

     1.    How ground-water monitoring
          works

          a.   Use of this method for
              piping is the same as its use
              for tanks, with the following
              exception:

              Additional wells will be
              needed to  monitor the area
              affected  by piping.

     2.    When is ground-water monitoring
          appropriate

          a.   LIST system characteristics

              Can be used to detect leaks
              from tanks and piping.

              May be used on any size
              piping run.  For larger sys-
              tems, more wells are added.

              May be retrofitted.  When
              retrofitting, installer must be
              cautious not to puncture
              piping.

          b.   Product characteristics

              Density must be lower than
              that of water. (Product must
              float on top of water.)
Slide 39:  Discuss ground-water monitoring as it
applies to piping.  Note that additional wells may
be added approximately every 10 to 20 feet of
piping run to monitor the piping system.
Slide 40:  Mention ground-water monitoring as it
applies to piping. Ground-water monitoring's
applicability for piping is the same as it is for
tanks.
                                                                     Chapter Five, Page 17

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 Lecture Notes
             Instructional Aids
     Product should not mix
     easily with water.  (If it
     mixes, no free product layer
     will form.)

     Most commonly used for
     gasoline and diesel fuels.
     (Alcohols and water-soluble
     chemicals are not
     appropriate.)

c.    Soil conditions

     If this method is used alone,
     soil between well and piping
     must be coarse and per-
     meable (for example sand or
     gravel).

d.    Climatic factors

     Very low temperatures may
     interfere with some
     monitoring devices.  Ice can
     freeze monitors and interfere
     with product-soluble
     devices.

e.    Geologic conditions

     Level  of ground-water table
     must not be more than 20
     feet below the surface.

          Ideally, the ground
          water should be
          between 2 and 10 feet
          from the surface.

     Fluctuations in water table
     level

          If water level falls below
          bottom of, or rises
          above the top of, the
          well screen, this
          method alone becomes
          insufficient to detect
          released product.

     If there is a steep gradient of
     ground-water flow, the
     product may  bypass the
     monitoring wells.
Slide 41:  Product must be a floater* vs. a
"sinker," and must not mix readily with water.
Most commonly used with gasoline and diesel
fuels.
Slide 42:  Explain the terms "porosity1 and
•hydraulic conductivity."  (Review these terms
from Chapter Three.)

Soil analysis may have to be conducted.
Slide 43:  Discuss climatic problems relating to
ground-water monitoring as they pertain to your
State (e.g., areas with high or low annual rainfall,
or extreme temperatures).
Slide 44:  Discuss geologic considerations.
Mention that it is essential to know the water
table level and gradient in order to have an
effective ground-water monitoring program.
                                                           Chapter Five, Page 18

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           Lecture Notes
             Instructional Aids
              Because free product tends
              to flow through fractures and
              cavities in the soil, wells that
              do not intercept these frac-
              tures and cavities will not
              detect free product.

     3.    Considerations

              Ground-water monitoring of
              underground piping can
              easily be integrated with a
              tank ground-water
              monitoring system.

C.   Vapor monitoring

     1.    How vapor monitoring works

          a.   Use of this method for
              piping is same as its use for
              tanks, with the following
              exceptions:

              Monitoring wells do not
              need to be as deep as
              those used for tank
              monitoring.

              When used for interstitial
              monitoring, horizontal slotted
              tubes at or below piping
              level may be used rather
              than  conventional vertical
              wells.

     2.    When vapor monitoring is
          appropriate

          a.   LIST system characteristics

              This method can be used
              for both tanks and piping.

              This method can be installed
              as part of new or existing
              tanks and piping.

              May be retrofitted. When
              retrofitting, installer must be
              cautious not to puncture
              piping.
Slide 45 (graphic): This graphic shows how the
well can be installed in what seems to be a good
place, but will still not detect a release due to
the geology.
Slide 46:  Discuss site assessments, detection
devices, and how to avoid damage to pipes
during installation.
Slide 47:  Discuss vapor monitoring as it applies
to piping.  Shallower wells than those used for
tanks may be used.

Applicability is the same for a tank system.

This method is easily integrated with an LIST
vapor monitoring system.
Slide 48: General applicability.
                                                                     Chapter Five, Page 19

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 Lecture Notes
             Instructional Aids
b.   Product characteristics

     Vapor monitoring must be
     used with products that
     vaporize readily. For
     example, gasoline, diesel
     fuel, and aviation fuels are
     appropriate, but residual oil
     No. 6 (used oil) is not.

c.   Soil conditions

     The backfill around the
     pipes must be porous
     enough to allow the vapors
     to reach the monitoring
     wells.

     Backfill and nearby soil must
     be clean and should not
     contain substances that will
     produce vapors.

          Previously con-
         taminated soil may lead
         to false readings,
          indicating releases.

d.   Climatic factors

     Temperature affects the
     volatility of released  product.
     Sensors may need to be
     adjusted for extreme
     temperatures.

e.   Geologic conditions

         This method cannot be
          used in areas with
          heavy annual rainfall,
         extremely moist cli-
         mates or high ground
         water.
Slide 49:  Give examples of fuels that are most
appropriate for vapor monitoring due to their
high volatility (e.g., alcohol, jet fuels).
Slide 50:  Discuss how backfills can distort
results, such as previous soil contamination.
Soil type can affect how the vapor can travel.
Slide 51  (graphic): This graph demonstrates
the effects of soil conditions on vapor con-
centrations at a vapor monitoring well. The ver-
tical axis is gasoline in ppm, the horizontal axis
represents time in days.  Note that the vapor
concentrations are much lower in wet sand or
clay vs. the dry backfill.  These are all readings
taken from the same release,  at the same dis-
tance from the source.

Slide 52:  Discuss slide.
Slide 53:  Moisture-related considerations.
                                                            Chapter Five, Page 20

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                Lecture Notes
           Instructional Aids
—     The water fills spaces between the soil
       particles, preventing vapor from travelling
       through the soil. Vapors may also dissolve
       in the moisture before reaching the
       monitors.

3.     Considerations

—     Vapor monitoring for underground piping
       can easily be integrated with a tank vapor
       monitoring system.

D. Statistical Inventory Reconciliation (SIR)

The three monthly monitoring methods described so
far were all identified in the Federal regulations that
became effective in December 1988. The
regulations provided, however, that other release
detection methods could be approved in the future if
those methods could meet EPA's performance
standards for release detection.  In June 1990, EPA
published a standard test procedure for an
additional release detection method that is known
as Statistical Inventory Reconciliation (SIR).  SIR
methods must be evaluated using EPA's standard
test procedure or an equivalent procedure to prove
they can  meet EPA's release detection performance
standards.

Chapter Four described the applicability of SIR to
leak detection for tanks.  Methods, applications, and
considerations of SIR for piping systems are similar
to those for tanks.

1. How SIR works

Statistical inventory reconciliation (SIR) analyzes
inventory, delivery, and dispensing data collected
over a period of time to determine whether or not a
tank system is leaking.

a.       Each operating day the operator measures
        the product level using a gauge stick or
        other tank level gauge. A calibration chart
        specific to the tank is used to convert
        product level  into product volume.

—      The operator also keeps complete  records
        of all withdrawals from the LIST and of
        deliveries to the LIST.
Slide 54: Can easily be integrated with tank vapor
monitoring system. Discuss any other considera-
tions relevant to your State.
Slide 55:  Discuss basic SIR operation.
                                                                           Chapter Five, Page 21

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                 Lecture Notes
           Instructional Aids
—      After data have been collected for the period
        of time required by the SIR vendor, this
        information is provided to the SIR vendor.

b.      The SIR vendor uses sophisticated
        statistical software to conduct an analysis of
        the data that can identify if the UST is
        leaking.

c.      Every month, the SIR vendor reports the
        results of the analysis to the operator, who
        keeps monthly reports on file for at least 12
        months.

d.      The Federal requirements for monthly
        release detection are met if the SIR analysis
        is performed every month, is capable of
        detecting release rates of at least 0.2 gallons
        per hour (with a probability of detection of
        0.95 and a probability of false alarm of 0.05),
        and the results are available at the UST
        facility on a monthly basis. State and local
        requirements can be more
        restrictive.

2.      When SIR is appropriate

a.      UST system characteristics

—      SIR procedures apply to fueling sites where
        the required measurements can be taken
        every operating day. It is not appropriate for
        unattended facilities, unless the required
        data can be retrieved remotely.

b.      Product characteristics

—      SIR is generally not restricted by product
        type.

c.      Soil conditions

—      SIR is not affected by soil type.
        Climatic factors

        Changes in climate, especially temperature,
        affect the data used in SIR, so SIR providers
        must take climatic factors into consideration
        in their procedures.
Slide 56:  Discuss these characteristics.
                                                                            Chapter Five, Page 22

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         Lecture Notes
           Instructional Aids
Geologic conditions

SIR for piping is not affected by geologic
conditions.

Considerations

SIR can be used for tank and piping
systems.

SIR should not be confused with other
release detection methods that also rely on
periodic reconciliation of inventory,
withdrawal, or delivery data. Unlike manual
tank gauging, automatic tank gauging
systems, and inventory control (described
earlier in Chapter Four), SIR uses a
sophisticated statistical analysis of data to
detect releases.  This statistical analysis
can only be done by competent vendors of
SIR systems.

The procedures used by the SIR vendor
must be evaluated against EPA's standard
test procedures (or an equivalent protocol)
to confirm that the procedures are capable
of meeting the Federal regulatory
requirements regarding the detection of
minimum release rates and the probabilities
of detection and false alarm.

Tank level and meter readings should be
taken carefully at the same time each
operating day, at a time when  no product is
being delivered or dispensed.  SIR does not
require that the tank be out of service for
extended periods.

Data can be transmitted to the SIR vendor
on paper or by using computer modems or
diskettes.

SIR can identify problems other than
leaking systems, such as miscalibrated
meters, tilted tanks, and loss resulting from
theft.
Slide 57:  Discuss these considerations.
Slide 58: Discuss these considerations.
                                                                    Chapter Five, Page 23

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         Lecture Notes
Instructional Aids
SIR requires minimal investment of staff time
and equipment costs (usually involving gauge
stick and pastes that help identify product and
water levels). The cost of services provided
by SIR vendors compares favorably with the
cost of other leak detection methods.

State and local governments can place
restrictions on the use  of SIR for compliance
purposes.
                                           Slide 59:  Review LIST piping. Answer questions.
                                                                   Chapter Five, Page 24

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                          GLOSSARY OF LEAK DETECTION TERMS


Ambient temperature - Temperature of areas surrounding the tank site.

Atmospheric pressure - The weight of overlying air at any given location.

Backfill - The material used to fill in the excavation zone after the tank is in place.  The best
installation practice is to use sand or gravel as specified.

Check valve - The valve found in suction piping systems that closes when product begins to flow
backwards through the pipe.

Compatibility - The ability of a tank and piping to  be unaffected by stored product.

Contamination --  The remains, liquid or vapor, in soil or backfill of releases at a site.

Density - The mass of a given substance per unit volume.

DNAPLs  - Dense non-aqueous phase liquids.

Excavation liners - Flexible sheets of relatively impermeable substances (possibly made of various
synthetic materials, such as high-density polyethylene, polyester elastomers, epichlorohydrin, and
polyurethane) that separate the UST system and backfill from the native soil of the site.

Excavation zone ~ The entire  area that must be dug up in order to install an UST.

Fill pipes -- The pipes connecting the underground tank to an aboveground fitting where a tank truck
connects its transfer hose.

Free product ~ The leaked product floating on the water table surface.

Grab samplers  -- The bucket or bailer used to obtain ground-water samples,  from monitoring wells.

Hydraulic conductivity - The  measurement of the rate at which a liquid can flow through a particular
material, such as soil.

Interstitial space - The space between the wall of the tank or pipe and the secondary container or
lining.

Inventory control ~ A comparison of what is actually in the tank, based on measurement, to what
should be in the tank, based on records.

Overages - The amount by which volume measurement exceeds what is expected.

Overfill method - A method used on tank tightness testing during which the  tank is filled until the
level of the  product reaches the fill tube or a standpipe located above grade.

Performance standard - The  minimum sensitivity  of a method as specified in the regulation.

Permeability - A measurement of the ability of backfill or soil to permit liquids or gases to pass
through.

                                                                           Appendix I, Page 1

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Porosity - The measurement of the extent to which a material contains small spaces through which
vapors or.liquid can pass.

Positive displacement pump - The pump placed at or near the point of end use on suction piping
systems; this pump creates a vacuum which draws product from the tank to the pump.

Pressurized piping systems -- These systems use a pump at the bottom of the tank to push the
product to the  dispenser.

Product delivery lines - The piping that connects tanks and product dispensers (pumps).

Product-finding paste - Paste applied over a gauge stick to improve adherency of the product to the
stick and prevent creepage. The pastes change color in the presence of product, and  are applied in
the area where one expects to see the product line, not on the entire stick.

Remote fill - Piping runs leading to a storage area for wastes, such as used oil,  that are generally
installed as an  afterthought, which therefore, are prone to leaks.

Restrictors -- Devices that keep the flow of product from the pump to the point of use below a certain
gal/h rate.

Retrofit - The  process of upgrading an UST system with new technologies and/or products.

Shortage -- The amount that the volume measurement is below what is expected.

Solubility - The ability of a substance to dissolve in or mix with another substance.

Static tank system - A tank that is not in use; no product is added or removed.

Suction piping - The system uses a vacuum to draw the product from the tank to the pump.

Tank deformation -- Expansions and contractions of the tank resulting from fluctuating  temperatures
of product within the tank and from the addition of product to the tank.

Thermal properties - Changes in product characteristics that occur in response to an  increase or
decrease in temperature.

Underground storage tank (UST) - A system used to store and dispense petroleum products. An
UST system includes the tank(s), piping, and product dispensers. At least 10 percent of the
combined volume of the tank(s) and associated piping must be underground for the system to be
considered an  UST system.

Vapor pockets - Vapor that becomes trapped in the manways, deadend piping, etc., after a tank has
been filled to or above the top of the tank.

Vapor recovery lines - Pipes that carry vapors back to the tank truck during off-loading, or back to
the UST during product dispensing.

Vent pipes - Pipes routed to the surface as aboveground vents.

Viscosity - The measurement of the ease with which a liquid flows.


                                                                         Appendix I, Page 2

-------
Volatility -- The measurement indicating how readily a substance will vaporize.

Water table -- The level where ground water will rest in porous soil conditions under normal
atmospheric pressure.

Well screen - The perforated or slotted area of a well that allows product to enter the well.
                                                                            Appendix I, Page 3

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                                   CASE STUDY GUIDELINE
I.      INTRODUCTION

       The following guideline has been provided to help you develop a case study tailored to the
specific needs of each training session that can be used by participants to increase their
understanding of the leak detection requirements. This course is designed to be flexible, allowing you
to include your own 'designer* case study exercise in place of or in addition to the other exercises
provided in Appendix II.  The goal of the case study is to apply the UST system characteristics and
regulatory information presented throughout the course to an actual or fictitious UST facility.

II.      GUIDELINE FOR DEVELOPING A CASE STUDY

 A.    Identify the purpose of the case study.

       1.     What specific topics do you want to cover?

       2.     How much time are you allowing for the case study?

       3.     Have you considered your audience carefully (for example, their level of prior
              knowledge in their field or their expectations for the training)?

 B.    Select an UST site.

       1.     Do you want an actual site or a fictitious site?

       2.     What characteristics are important about the site:  UST system characteristics,
              product characteristics, soil conditions, climatic factors, and geologic conditions?

       3.     Locate or create slides and maps of the site.

 C.    Develop a list of pertinent information that participants will need in order to make decisions
       about the leak detection method at the site.

       1.     Have list ready prior to presentation  of case study, or

       2.     Incorporate this task into the presentation of the case study as a group discussion.
              You may want to use the "UST Site Characteristics' exercise found  on pages 3 and 4
              of this Appendix,

 D.    Break students into small groups.  Provide a list of questions or issues to be addressed  based
       on the topics that you have chosen for the case study. Discussion topics may include:

       •     Determining the important site characteristics at the case study's site.

       •     Comparing UST leak detection methods in terms of suitability to the site, cost, ease of
              use, and amount of time required for operation or maintenance.

       •     Determining the appropriate  leak detection method for the site.
                                                                           Appendix II, Page 1

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      Each group can discuss all questions, or each group can be assigned a specific
      question/issue. Groups can prepare to present and justify their decisions to the whole class
      based on regulations and materials presented in the course. Remind students that the
      student manual should be used to check for the regulatory requirements.

E.    Evaluate group decisions, making sure that all regulations and measures have been
      addressed for the UST site being considered. This would be an appropriate time for open
      group discussion and other suggestions.
                                                                         Appendix II, Page 2

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                         EXERCISE - UST SITE CHARACTERISTICS
       You are the UST "hotline" person for your State.  UST owners and operators call you for
information on leak detection methods.  The UST systems range from a single tank and large service
station systems to military installations.  In order to make decisions and answer questions correctly,
you will need to know some information about the UST in question.

       Develop a list of questions that you will use to obtain necessary information about the UST.
Consider the site characteristics discussed in the training manual, as well as logistical information that
you may want for your records.
                                                                          Appendix II, Page 3

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                 SAMPLE LIST OF 'UST SITE CHARACTERISTICS" QUESTIONS


1.      Name of owner/operator. Are you the owner or operator?
2.     What is the purpose of the UST? (Service station, city installment.) Site location? (State,
       county, city; for specific local regulations).
3.     How many tanks are in question?
4.      What is the date of tank installation? (May have to be approximate.)
5.      Types of tanks.  (May be more than one type.)
6.      Size of tanks. (May be more than one size; therefore, different regulations may apply.)
7.      Types of piping system in the UST. (Where is the pump located?)
8.      What types of product are handled?
9.      What is the backfill around the tanks?  (Describe.  Was it local fill or specifically delivered for
       the UST?)
10.     What is the soil type and ground-water level (if known)?
11.     Is there any leak detection system used now?  Describe.
12.     If a leak is suspected, what indications do you have?
                                                                         Appendix II, Page 4

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                                      EXERCISE - ATGS
Review the scenario described in the following situation. You should decide individually, and then as
a group, what could be causing the described problem.
Scenario

Sal Robinson owns a small tank facility in
southern Louisiana.  The tanks range from
7,000 to 15,000 gallons in size, and contain
heating oil and diesel fuel.  Sal purchased the
facility in 1988.  At that time, manual inventory
control was the leak detection method used.
No leaks had been detected using this
method.  Two months ago Sal installed an
ATGS into the tank system.  His records now
indicate substantial leaks in the UST system.
In your discussion you have found out that his
area is suffering a severe drought, a real shock
for an area with such a high annual rainfall.
Sal is concerned and confused about the new
leak detection method and the results that are
being obtained.
What suggestions do you have that may
explain the results? (Consider that the results
may be either true or false.)
                                                                          Appendix II, Page 5

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                                      EXERCISE - ATGS
                                      (Instructor's Copy)
Review the scenario described in the following situation.  Students should decide individually, and
then as a group, what could be causing the described problem.  Lead a group discussion, making
sure that all relevant points are considered, and that the students fully understand the reasoning upon
which decisions were made.
Scenario

Sal Robinson owns a small tank facility in
southern Louisiana.  The tanks range from
7,000 to 15,000 gallons in size, and contain
heating oil and diesel fuel.  Sal purchased the
facility in 1988.  At that time manual inventory
control was the leak detection method used.
No leaks had been detected using this
method. Two months ago Sal installed an
ATGS into the tank system.  His records now
indicate substantial leaks in  the UST system.
In your discussion you have found out that his
area is suffering a severe drought, a real shock
for an area with such a high annual rainfall.
Sal is concerned and confused about the new
leak detection method and the results that are
being obtained.
What suggestions do you have that may
explain the results? (Consider that the results
may be either true or false.)
Points to emphasize

•      The tanks may have been leaking for
       some time, but they were not being
       properly tested previously.

•      The tanks were leaking all along.
       However, due to the usually high
       amount of rainfall, the ground-water
       levels were high enough to mask the
       leaks. The area is now suffering from
       a drought, which may affect the level of
       ground water.

•      Staff may be making errors with the
       use of the new system.

•      Wiring of the ATGS may be improperly
       installed.

•      The temperature and volume
       calibrations may not be correct in the
       ATGS, giving false data.
                                                                          Appendix II, Page 6

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                         EXERCISE - GROUND-WATER MONITORING
Review the scenario described in the following situation.  You should decide individually, and then as
a group, whether ground-water monitoring is appropriate. Review the site characteristics mentioned in
Chapters Two and Three.
Scenario

Frank Lee has owned a small service station
near Lathrop Wells, Nevada, since 1958. All
four of the station's underground storage tanks
were installed at the time he bought the site.
The only products Frank stores in the tanks
are gasoline (both leaded and unleaded) and
diesel fuel.  The tanks are located in soil that
consists of welded volcanic ash (or tuff) that
extends for several hundred feet below the
surface. The climate at the site (not far from
Death Valley) is generally arid, and
temperatures can exceed  110 degrees
fahrenheit during summer days. On the other
hand, sub-freezing temperatures at night are
not uncommon during winter months.
Is ground-water monitoring an appropriate leak
detection method in Frank's case? Why or
why not?
What further information, if any, do you need
from Frank, to determine this?
                                                                          Appendix II, Page 7

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                         EXERCISE -- GROUND-WATER MONITORING
                                       (Instructor's Copy)
Review the scenario described in the following situation. Students should decide individually, and
then as a group, whether ground-water monitoring is appropriate.  Review the site characteristics
mentioned in Chapters Two and Three.
Scenario

Frank Lee has owned a small service station
near Lathrop Wells, Nevada, since 1958.  All
four of the station's underground storage tanks
were installed at the time he bought the site.
The only products Frank stores in the tanks
are gasoline (both leaded and unleaded) and
diesel fuel.  The tanks are located in soil that
consists of welded volcanic ash (or tuff) that
extends for several hundred feet below the
surface.  The climate at the site (not far from
Death Valley) is generally arid, and
temperatures can exceed 110 degrees
fahrenheit during summer days. On the other
hand, sub-freezing temperatures at  night are
not uncommon during winter months.
Is ground-water monitoring an appropriate leak
detection method in Frank's case? Why or
why not?
What further information, if any, do you need
from Frank, to determine this?
Points to emphasize

•      Is Frank required to have leak
       detection for his tanks now?

       [Yes, the tanks are 30 years old.]

•      Are the types of products Frank stores
       appropriate for a ground-water
       monitoring system?

       [Yes, both gasoline and diesel fuel
       have lower density than water, and do
       not mix easily with water.]

•      Is the geology at Frank's site
       appropriate for ground-water
       monitoring?

       [No, the water table is several hundred
       feet below the surface.]

•      Is the soil appropriate?

       [Unknown.  Need to inquire about
       conductivity of tuff.]

•      Is the climate appropriate?

       [Yes. Short-term temperature changes
       are not a problem.]

•      Is ground-water monitoring appropriate
       for Frank?

       [No. The water table is too low to
       allow floating free product to be
       detected.]

•      Is more information needed?

       [No. Low water table rules out ground-
       water monitoring.]
                                                                          Appendix II, Page 8

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                              EXERCISE - VAPOR MONITORING
Review the scenario described in the following situation.  You should decide individually, and then as
a group, whether vapor monitoring is appropriate for this situation.  Review the site characteristics
mentioned in Chapters Two and Three, along with the considerations for vapor monitoring.
Scenario

Joe Carlisle has owned a small airfield in
Green Lake, Wisconsin for 20 years.  He has
four USTs for various types of airplane fuels
that are all near the airfield.  Near the hangers
are diesel, unleaded and leaded gasoline
tanks, and near the maintenance shop is one
750-gallon storage tank for used oil.  The tanks
are installed in a glacial outwash area, which
consists of unsorted sands and gravels.  The
depth of the water table averages 15 feet, and
remains fairly  constant. An airplane owner has
suggested that instead of the time consuming
method of manual tank gauging, that Joe
consider vapor monitoring for the entire area.
Is vapor monitoring appropriate for this case?
Is there any other information that you might
need to make your decision?
                                                                           Appendix II, Page 9

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                               EXERCISE • VAPOR MONITORING
                                      (Instructor's Copy)
Review the scenario described in the following situation. Students should decide individually, and
then as a group, whether vapor monitoring is appropriate for this situation. Review the site
characteristics mentioned in Chapters Two and Three, along with the considerations for vapor
monitoring.  Lead the group discussion, making sure that all of the relevant points are considered.
Scenario

Joe Carlisle has owned a small airfield in
Green Lake, Wisconsin for 20 years. He has
four USTs for various types of airplane fuels
that are all near the airfield. Near the hangers
are diesel, unleaded and leaded gasoline
tanks, and near the maintenance shop is one
750-gallon storage tank for used oil. The tanks
are installed in a glacial outwash area, which
consists of unsorted sands and gravels. The
depth of the water table averages 15 feet, and
remains fairly constant. An airplane owner has
suggested that  instead of the time consuming
method of manual tank gauging, that Joe
consider vapor  monitoring for the entire area.
Points to emphasize
       The stored product: While the airplane
       fuel, gasoline, and diesel fuels are
       appropriate for vapor monitoring, the
       used oil is not, due to its low volatility.

       Soil conditions:  The glacial outwash
       provides adequate porosity for vapor
       travel, and  is therefore appropriate for
       vapor monitoring.

       Ground water: The level of ground
       water is appropriate, and does not
       fluctuate greatly, and is therefore
       appropriate for vapor monitoring.
Is vapor monitoring appropriate for this case?
Is there any other information that you might
need to make your decision?
                                                                          Appendix II, Page 10

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Appendix II, Page 11

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Slide Section
             Appendix III, Page 1

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     CHAPTER 1-1



BASIC LEAK DETECTION

-------
                    SLIDE 1-2
              BASIC LEAK DETECTION
   Overview of leaking USTs



   The need for leak detection
•  Leak detection methods

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                    SLIDE 1-3

     DISTRIBUTION OF TANK TYPES AT
       GASOLINE SERVICE STATIONS
 Bare Steel
  (84%)
  NOT
PROTECTED
 AGAINST
  LEAKS
                                    Cathodically Protected
                                         (5%)
                                          PROTECTED
                                           AGAINST
                                            LEAKS
                                      Fiberglass-Reinforced
                                        Plastic (11%)
Source: Regulatory Impact Analysis. August 24,1988.

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                     SLIDE 1-4
            OVERVIEW OF LEAKING USTs
The Problem
•  15-20 percent of petroleum tanks may be leaking
•  Leaking tanks pose a threat to ground water and
   surface water

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                     SLIDE 1-5



          THE PROBLEM OF LEAKING USTs





The threat of leaking tanks also applies to



•  Contamination of surface waters



•  Fires and explosions



•  Toxic fumes



•  Cancer causing agents

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                     SLIDE 1-6
               CAUSES OF RELEASES
Releases result from
•  Piping failures
•  Spills and overfills
•  Tank corrosion

-------
               SLIDE 1-7
WHERE RELEASED PRODUCT TRAVELS
                              Water Supply
                              Well
Groundwater Flow
Dissolved
Gasoline
Components
Bedrock

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                   SLIDE 1-8
        USES OF REGULATED USTs
           Used Oil
           (20%)
Chemical Storage
   (3%)
                                        Retail Motor Fuels
                                           (39%)
         Non-Retail
       Motor Fuels (38%)

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             SLIDE 1-9

    OWNERSHIP OF USTs USED
      TO STORE PETROLEUM
   Government
     (11%)
Farmers
 (11%)
Industry
 (39%)
             Gas Stations
               (39%)

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                    SLIDE MO


     WHAT CAN LEAK DETECTION ACCOMPLISH?


Leak detection

•  Warns owner or operator of leaks

•  Prevents contamination of the environment and
   risks to human health

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                 SLIDE 1-11



    WHY IS LEAK DETECTION NECESSARY?





Leak detection can help save money in the long run



The average cleanup now costs $150,000

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                    SLIDE 1-12
       WHY IS LEAK DETECTION NECESSARY?
Leak detection
•  Is a good business practice
•  Protects human health and the environment
•  Protects against liability suits
•  Is required by Federal, State, and local laws

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                     SLIDE 1-13



             LEAK DETECTION METHODS





Three main types of leak detection



•  Internal Monitoring



•  Interstitial Monitoring



•  External Monitoring

-------
                      SLIDE 1-14
                INTERNAL MONITORING
Internal monitoring methods



•  Inventory control combined with tightness testing



•  Manual tank gauging



•  Automatic tank gauging



•  Statistical inventory reconciliation

-------
                     SLIDE 1-15



             INTERSTITIAL MONITORING





Interstitial monitoring method



•  Secondary containment with interstitial monitoring

-------
                    SLIDE 1-16
              EXTERNAL MONITORING
External monitoring methods
•  Vapor monitoring
•  Ground-water monitoring

-------
                  SLIDE 1-17

             PIPING MONITORING
Pressurized and suction piping have different
compliance time tables and testing requirements

Pressurized piping must have automatic line leak
detectors

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                     SLIDE 1-18

       LEAK DETECTION METHODS FOR PIPING


Leak detection methods for piping operate on the same
principles as those for tanks

•  Tightness testing

•  interstitial monitoring

•  External monitoring

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                 SLIDE 1-19



           BASIC LEAK DETECTION
Overview of leaking USTs



The need for leak detection



Leak detection methods

-------
   CHAPTER 11-1



UST WALK-THROUGH

-------
                   SLIDE 11-2



WHAT IS AN UNDERGROUND STORAGE TANK (UST)?





i  A system used to store petroleum products



i  Includes the tank, piping, and product dispensers

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                       SLIDE 11-3
      TYPICAL RETAIL GASOLINE STATION
                                                   Vent Pipes
            Tank Truck
      Delivery Hose
Submerged Pump
  Assembly
Line Leak
Detector
                                             Submerged Pump
                                                Assembly
     Product Dispensers
                            Product Delivery Line

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                     SLIDE 11-4

                 USE EXCEPTIONS

Certain USTs are not required to comply with Federal UST
regulations.

•  Farm or residential tanks 1,100 gallons or less
   storing motor fuel for noncommercial purposes

•  Tanks storing heating oil for consumptive use on
   the premises where stored

•  Tanks holding 110 gallons or less

•  Tanks on or above the floor of underground areas

•  Septic tanks and systems for collecting storm
   water and waste water

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                    SLIDE 11-5



                 UST EXCEPTIONS





•  Flow-through process tanks



•  Emergency spill and overfill tanks



•  Surface impoundments, ponds, pits, or lagoons

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                     SLIDE 11-6



                UST SYSTEM PARTS





TANKS



•  Typical tanks hold between 2,000 and 12,000 gallons



•  New tanks are generally constructed of:



   --  Cathodically protected coated steel



   -  Fiberglass-reinforced plastic (FRP)



   -  Steel/fiberglass composite

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                  SLIDE 11-7

          VAPOR RECOVERY LINES
Pipes that convey petroleum vapors back to the tank
trucks during off-loading or back to the LIST during
dispensing of product

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                  SLIDE 11-8

             SITE TERMINOLOGY
Excavation zone

--  Area that must be dug up to install an UST

Backfill

--  Substance (usually clean sand, crushed rock, or
   pea gravel) used to fill in excavation zone after
   tank is installed

Water Table

--  Level where ground water will rest in porous soil
   conditions under normal atmospheric pressure

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               SLIDE 11-9

   SCHEMATIC OF A SUBSURFACE
            ENVIRONMENT
          ( TANK )
Excavation
  Zone
                                    Dry
                                    Soil
                    Released
                    Product
      t
     Water Table
                               Aquifer
sZfxZfy&fy&fSfxS&fS^
             Impermeable Boundary

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                 SLIDE 11-10

              WHAT IS AN UST?
A system used to store and dispense petroleum
products

Includes the tank, piping, and product dispensers

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    CHAPTER 111-1



SITE CHARACTERISTICS

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                      SLIDE 111-2


Important site characteristics that should be considered
when selecting the proper leak detection method

•  UST system characteristics

•  Product characteristics

•  Soil conditions

•  Climatic factors

•  Geologic conditions

-------
                 SLIDE 111-3



       UST SYSTEM CHARACTERISTICS





Tank age (new vs. existing)



Tank size



Piping system



UST system size

-------
                  SLIDE 111-4

                  TANK AGE
New tanks and piping are those installed after
December 23, 1988

Existing tanks and piping are those installed before
December 23, 1988

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              SLIDE IM-5
AGE OF TANK

Existing Tanks
Installed:

Before 1965 or
unknown

1965-1969

1970-1974

1975-1979

1980-1988
LEAK DETECTION
Must have leak detection
by:
December 1989
December 1990
December 1991
December 1992
December 1993

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                 SLIDE 111-6

                 TANK SIZE
Check tank size - some tanks may be too large to
use certain detection methods

-------
                 SLIDE 111-7

               PIPING SYSTEM
Suction systems use a vacuum to draw the product
to the dispenser

Pressurized systems use a pump to push the product
to the dispenser

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                 SLIDE 111-8
              UST SYSTEM SIZE
Number of tanks
Extent of site area

-------
                SLIDE 111-10
        TYPES OF STORED PRODUCTS
Petroleum
Hazardous substances
--  Include CERCLA hazardous substances
--  Do not include hazardous wastes regulated under
   40 CFR Parts 260-270
--  Use secondary containment for hazardous
   substances

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                 SLIDE 111-11
         PRODUCT CHARACTERISTICS
       IMPORTANT IN LEAK DETECTION
Solubility
Density
Viscosity
Volatility
Thermal effects
Compatibility with tank and piping materials

-------
                   SLIDE 111-12

     CHARACTERISTICS OF STORED PRODUCTS
Solubility
   The ability of a substance to dissolve in or mix with
   another substance

-------
                   SLIDE 111-13

     CHARACTERISTICS OF STORED PRODUCTS
Density
   Refers to the mass of a given substance per unit of
   volume

-------
               SLIDE 111-14
    *



  CHARACTERISTICS OF STORED PRODUCTS







Gasoline floats on water; DNAPLs do not float

-------
                  SLIDE 111-15



     CHARACTERISTICS OF STORED PRODUCTS





Viscosity



•  A measurement of the ease with which a liquid flows

-------
                   SLIDE 111-16

     CHARACTERISTICS OF STORED PRODUCTS
Volatility
   A measurement indicating how readily a substance
   will vaporize

-------
                    SLIDE MM 7

     CHARACTERISTICS OF STORED PRODUCTS
Thermal effects

•  Refers to changes in product characteristics that
   occur in response to an increase or decrease in
   temperature

Compatibility

•  The ability of a tank and piping to be unaffected by a
   stored product

-------
                  SLIDE 111-18
              SOIL CONDITIONS
Relative porosity
Hydraulic conductivity
Contamination

-------
                 SLIDE 111-19

             RELATIVE POROSITY
A measurement of the extent to which a material
(e.g., soil or backfill) contains small spaces through
which vapors or liquids can pass

-------
             SLIDE 111-20

THE EFFECT OF SOIL CONDITIONS ON
VAPOR CONCENTRATIONS AT A WELL
8000
                             Dry gravel backfill
                             Dry sitty sand
                             Moist sand backfill
                             Wet sand or clay
            10       20
            Number of Days
30

-------
                 SLIDE 111-21

          HYDRAULIC CONDUCTIVITY
A measurement of the rate at which a liquid
(e.g., water) can flow through a particular material
such as soil

-------
                 SLIDE 111-22



              CONTAMINATION
Soil or backfill may be contaminated by past releases

-------
                 SLIDE 111-23
             CLIMATIC FACTORS
Temperature
Rainfall

-------
                 SLIDE 111-24
           GEOLOGIC CONDITIONS
Effects of ground water
Important ground-water variables

-------
                SLIDE 111-25

       PRESENCE OF GROUND WATER
Presence of ground water may mask an actual leak or
slow the rate of the leak

-------
                SLIDE 111-26
THE EFFECT OF GROUND WATER ON THE
   RATE AND FLOW THROUGH A HOLE
                IN AN UST
                Water table above level of
                leak. Ground water enters
                 tank through hole.
           Water
           Table
              Water table below level of tank,
               Product escapes from hole.
         Water Tab*

-------
                 SLIDE 111-27



           GROUND-WATER TABLE





Depth of water table



Large fluctuations in water table levels



Gradient of ground-water flow

-------
                     SLIDE 111-28

SITE CHARACTERISTICS TO CONSIDER WHEN SELECTING
             A LEAK DETECTION METHOD
    UST system characteristics

    Product characteristics

    Soil conditions

    Climatic factors

    Geologic conditions

-------
          CHAPTER IV-1



LEAK DETECTION METHODS FOR TANKS

-------
                 SLIDE IV-2

   ALLOWABLE LEAK DETECTION METHODS


Monthly leak detection methods

-  Automatic tank gauging
--  Manual tank gauging
--  Secondary containment with interstitial monitoring
--  Ground-water monitoring
--  Vapor monitoring

Inventory control and tank tightness testing

-------
                     SLIDE IV-3

REQUIREMENTS FOR LEAK DETECTION FOR UST TANKS
There are different leak detection deadlines for new and
existing UST tanks:

•   New tank deadlines

    --  MUST comply with UST leak detection when
       installed

•   Existing tank deadlines

    --  must comply with the requirements according to
       the following timetable (next slide):

-------
             SLIDE IV-4
AGE OF TANK

Existing Tanks
Installed:

Before 1965 or
unknown

1965-1969

1970-1974

1975-1979

1980-1988
LEAK DETECTION
Must have leak detection
by:
December 1 989
December 1990
December 1991
December 1992
December 1993

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                  SLIDE IV-5

      LEAK DETECTION FOR NEW TANKS
Monthly monitoring (ATGS, manual tank gauging,
secondary containment with interstitial monitoring,
ground-water monitoring, vapor monitoring)

Monthly inventory control and tank tightness testing
every five years.  (This choice can be used only for
ten years after installation)

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                  SLIDE IV-6

    LEAK DETECTION FOR EXISTING TANKS
Monthly monitoring

Monthly inventory control and tank tightness testing
every five years. (Can be usved for only ten years
after adding corrosion protection and spill/overfill
prevention or until December 1998, whichever date is
later)

Monthly inventory control and annual tank tightness
testing (this can be used only until December 1 998)

-------
                 SLIDE IV-7

           PD/PFA REQUIREMENTS
Some methods must be capable of detecting a
specified leak rate or quantity with a probability of
detection (PD) of 0.95 and a probability of false alarm
(PFA) of 0.05

By December 1990,  automatic tank gauging systems
and tightness tests for tanks or piping must meet
PD/PFA requirements

By September 1991, automatic line leak detectors
must meet PD/PFA requirements

-------
                    SLIDE IV-8



LEAK DETECTION METHODS -- MONTHLY MONITORING





Five monthly monitoring methods:



•  Automatic tank gauging



•  Manual tank gauging



•  Secondary containment with interstitial monitoring



•  Ground-water monitoring



•  Vapor monitoring

-------
                 SLIDE IV-9



   FOR EACH RELEASE DETECTION METHOD





Brief description of how the method works



When the method is appropriate



Considerations for owners/operators

-------
                 SLIDE IV-10

HOW AUTOMATIC TANK GAUGING SYSTEMS WORK
 Continuously measure and record product level and
 temperature in tank

 Measure volume change over time.  If it decreases
 significantly, there may be a leak

-------
                       SLIDE IV-11
SCHEMATIC OF AN AUTOMATIC TANK GAUGING SYSTEM
                    REMOTE ATG MONITOR
                                            PUMP OR PUMP
                                           CONTROL CONSOLE
              FILL PIPE
                                  (OPTIONAL WIRING)

-------
                  SLIDE IV-12



  HOW AUTOMATIC TANK GAUGING SYSTEMS WORK





•  Inventory control mode



•  Leak testing mode

-------
                SLIDE  IV-13
GENERAL PROCEDURE  FOR ATGS
 I
 N
 S
 T
 A
 L
 L
 A
 T
 I
 0
 N
        Install equipment
                 - Probes in tanks
                 - Monitor nearby
        Program monitor
                 - Tank depth and volume chan
                 - Test times
                 - Alarm levels
               Shutdown tank operations
 TESTING
 OR
 INVENTORY
                 - Temperature to reach
                  equilibrium
                 - Tank deformation to sut
                 Make temperature
                    and level
                  measurements
                          \
 TESTING
 A
 N
 A
 L
 Y
 S
 I
 S
 Reconcile
inventory data
           Apply
          detection
           criteria

-------
                    SLIDE IV-14

  HOW AUTOMATIC TANK GAUGING SYSTEMS WORK


Inventory control mode

•  Automatically records activities of an in-service tank,
   including deliveries

   --  Product level and temperature readings are
      automatically taken and are converted to volume
      measurements. Data used in inventory control

   --  ATGS operate in this mode when leak test is not
      being performed

-------
                 SLIDEIV-15



           ATGS ALARM SYSTEMS





ATGS alarms notify owners/operators of:



--  High and low product levels



-  High water level



—  Theft of product

-------
                    SLIDE IV-16

  HOW AUTOMATIC TANK GAUGING SYSTEMS WORK


Leak testing mode

•  Product level and temperature measured generally at
   least two hours a month while tank not in use
•  Determines change in volume per hour, compares
   that value to an internal standard, and determines if
   UST is leaking or not

•  Test can be run at any level of product in tank

•  Tank must be out of service during the test

-------
                  SLIDE IV-17
        WHEN ATGS ARE APPROPRIATE

UST system characteristics
--  Primarily used for tanks with capacity less than
   15,000 gallons and cannot be used for piping
Product characteristics
--  Primarily used with gasoline or diesel
-  If used with larger size or other fuels, ask vendor
   for proof that the method is effective
Soil conditions
--  No restrictions exist

-------
                 SLIDE IV-18
       WHEN ATGS ARE APPROPRIATE
Climatic factors
--  Following delivery of fuel there is a six-hour
   waiting period (or longer, depending on climate)
Geologic conditions
--  Ground water covering all or part of a tank may
   mask a leak

-------
                  SLIDE IV-19
EFFECT OVER TIME OF TOPPING THE TANK WITH

              COLDER PRODUCT
O>
O
TJ
i

O
o>

a

O

£

»*

2
o
a.


o>
  0.50
  0.40
0.30
0.20 -
  0.10 -
  0.00
                                      214
                                         11
                       TIme-h

-------
                SLIDE IV-20
THE EFFECT OF GROUND WATER ON THE
    RATE OF FLOW THROUGH A HOLE
                IN AN UST
                Water table above level of
                leak. Ground water enters
                  tank through hole.
           Water
           Table
               Water table below level of tank.
               Product escapes from hole.
         Water Table

-------
                    SLIDE IV-21

                 CONSIDERATIONS
Tank level

•  No product should be delivered to tank for at least
   six hours before the monthly test

•  No product should be withdrawn from the tank for a
   few hours before the monthly test

•  No product can be withdrawn from or added to an
   UST during the monthly test, which lasts one to six
   hours

-------
                 SLIDE IV-22

              CONSIDERATIONS


ATGS requires little staff time

Some owners/operators find inventory control and
optional off-site monitoring features attractive

Tanks require a dedicated opening for the ATGS
probe, making retrofit difficult in some cases

-------
                    SLIDE IV-23

        HOW MANUAL TANK GAUGING WORKS


Short-term test in a static UST system

•  This test differs from inventory control, which
   requires daily recording volume in an active tank

•  Method cannot be used on tanks larger than 2,000
   gallons

-------
                    SLIDE IV-24



       HOW MANUAL TANK GAUGING WORKS





Product measured weekly with gauge stick



•  Test lasts up to 58 hours, depending on tank size



•  UST must be out-of-service during the test



•  Four measurements taken each week



   --  Two at beginning of the test



   -  Two at end of the test

-------

SLIDE IV-25
SAMPLE CALIBRATION CHART CONVERTING
PRODUCT DEPTH TO GALLONS*
^\Tank Size
Depth^^^
in Inches ^\^
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
550 Gal.
491/2" x 5'5"
2
7
13
20
29
37
47
57
68
79
90
102
115
127
140
1000 Gal.
491/2Mx 10'
4
13
24
38
52
68
86
104
124
144
165
187
209
232
255
1000 Gal.
64" x 6'
3
9
17
26
36
47
59
72
85
100
114
130
145
162
178
1500 Gal.
64" x 9'
4
13
25
39
54
71
89
108
128
150
172
195
218
243
268
2000 Gal.
64" x 12'
6
18
34
52
75
94
119
144
171
200
229
260
291
324
357
* Note that product depth in left column converts to gallons in the other
columns.


-------
                SLIDE IV-26

    HOW MANUAL TANK GAUGING WORKS


Calibrations converted to product volume

Average of first two measurements - Average of final
two measurements = Change in product volume over
time

Compare calculated tank volume change to weekly
and monthly standards to determine whether
discrepancy indicates leak

-------
SLIDE IV-27
WEEKLY AND MONTHLY STANDARDS
FOR VOLUME CHANGE
Tank Weekly
Capacity Change
(gal.) (gal.)
Up to 550 10
551 - 1 ,000 (64"x73") 9
1,000(48"x128") 12
If MTG is combined with TTT:
1 ,001 - 2,000 26
Monthly
Standard
(gai.)
5
4
6

13
Test
Duration
(hrs.)
36
44
58

36

-------
                    SLIDE IV-28

   WHEN MANUAL TANK GAUGING IS APPROPRIATE
UST system characteristics

•  Used only with tanks with capacity less than 2,001
   gallons

   --  Tanks smaller than 1 ,001 gallons may use this
      method alone for the life of the tank

   --  Tanks between 1 ,001 and 2,000 gallons must also
      use periodic tank tightness testing. Combined
      method can be used only for ten years following
      installation or upgrade.  Not allowed after 1998 for
      existing, non-upgraded tanks

-------
                    SLIDE IV-29
   WHEN MANUAL TANK GAUGING IS APPROPRIATE
Product characteristics
•  Not restricted
•  Works best with heavier fluids (e.g., used oil)
Soil conditions
•  Not restricted

-------
                   SLIDE IV-30

   WHEN MANUAL TANK GAUGING IS APPROPRIATE


Climatic factors

•  Ambient temperature changes may affect volume of
   stored product

•  If temperature change is great, testing period can be
   lengthened

-------
                   SLIDE IV-31

   WHEN MANUAL TANK GAUGING IS APPROPRIATE


Geologic conditions

•  Ground water may mask leak

•  Should not be used in areas with permanent high
   water table

-------
                 SLIDE IV-32
             CONSIDERATIONS
Frequency and length of test
-  Test must be performed at least once a week
-»  Testing period must last at least 36 hours
--  Owner/operator must remove UST system from
   service during test
Equipment costs are very low

-------
                 SLIDE IV-33

    HOW SECONDARY CONTAINMENT WITH
      INTERSTITIAL MONITORING WORKS
Secondary containment provides a barrier between
tank and surrounding environment

Interstitial monitors test for product in space between
tank and outer containment barrier

-------
         SLIDE IV-34
TANKS IN A CONCRETE VAULT
MAYOR
MAY NOT  H
BE
BACKFILLED
                          CONCRETE OR
                          ASPHALT SURFACE
                               CONCRETE
                                INTERIOR
                                LINING
                                SUMP
  SINGLE WALL TANK

-------
                SLIDE IV-35

      TWO DOUBLE-WALLED TANK
            CONFIGURATIONS
Sampling
Standpipe

  or

Electronic
Detection
  \
                                     • Out* Wail

                                      inrwr Wall
•OouWe-Walled Steel Tank
                        Interstitial Space
     ^ Illlllllll
             •Doubto-Wafled FRP Tank

-------
                              SLIDE IV-36
               TANK WITH EXCAVATION LINER
Monitoring Point Suitable
for Leak Detection and
Withdrawal of Accumulated
Water
            Pavement
                              Trench Top Liner
                                      Pipe Leak
                                      Detection
                                      Monitoring
                                      Point
                                               Collar to Connect
                                               Pipe Trench to
                                               Tank Liner
      Tank
  Excavation
      Liner
          Some
        Partially
  Enclosed Liners
  Would End Here
                                Trench Liner


                                Interstitial Space
Slotted Pipe for
Leak Detection and
Withdrawal of Water
                  Native Soil

-------
                 SLIDE IV-37
INTERSTITIAL MONITORING METHODS INCLUDE

Electrical conductivity
Pressure sensing
Liquid sensors
Hydrostatic sensing
Manual detection (dipstick)
Vapor monitoring

-------
                SLIDE IV-38

DOUBLE-WALLED TANK SHOWING PLACEMENT OF
      BOTH VAPOR AND LIQUID SENSORS
                                    Liquid Sensor

-------
                    SLIDE IV-39
      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
UST system characteristics
•  Can be used for both tanks and piping
•  Double-walled tanks are seldom larger than 20,000
   gallons
•  Excavation liners may be used around any size tank
*  Secondary containment is not practical for existing
   tanks and piping, except when an internal bladder is
   used for existing tanks

-------
                    SLIDE IV-40
      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
Product characteristics
•  Methods may be used for all fuel types, including
   hazardous substances
Soil conditions
•  No restrictions exist

-------
                    SLIDE IV-41

      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
Climatic factors

•  No restrictions.  However, in areas with heavy rainfall
   a fully enclosed  containment system should be used

Geologic conditions

•  In areas of high  ground water, a fully enclosed
   containment system should be used

-------
                     SLIDE IV-42

                  CONSIDERATIONS
Difficult installation

•  Installation of secondary containment using liners
   requires even more careful attention by professional
   installers than other leak detection methods

•  With the exception of internal bladders, retrofitting is
   basically impractical because it requires removing
   tank and piping entirely, installing a liner, and
   reinstalling tank

-------
                     SLIDE IV-43

                 CONSIDERATIONS


Compatibility of barrier with stored product

•  Exposure to product should not result in deterioration
   of barrier

•  For standard petroleum products such as gasoline
   and diesel fuel, most liners sold are compatible with
   product

•  For products other than petroleum, nature of product
   and type of barrier must be considered to ensure an
   appropriate match

-------
                     SLIDE IV-44

                 CONSIDERATIONS


Barrier may protect environment if leak occurs.

 • Low, if any, corrective action costs associated with this
   method.  This aspect differentiates this method from
   others by detecting leaks and containing them

-------
                     SLIDE IV-45

     HOW GROUND-WATER MONITORING WORKS


Monitoring wells

•  There are generally one to four wells per UST

•  Wells must be placed in, or near, backfill so that they
   can detect leaks rapidly

•  Well screen extends from the bottom of well to the
   highest water table level

•  On-site staff must check wells at least monthly for
   presence of leaked product floating on ground-water
   surface

-------
                  SLIDE IV-46
MONITORING WELLS WITH FILTER PACK
                               GROUND SURFACE
         WELL CAP
        VENT HOLE
      BENTONITE OR
      CEMENT GROUT
     WATER TABLE
      WELL SCREEN
      BOTTOM
      CASINO PLUG
PROTECTIVE STEEL
CASING
                                    ANNULAR SEAL
                                    FILTER PACK

-------
                    SLIDE IV-47

MONITORING WELL IN EXCAVATION ZONE
    Monitoring Well
Water Table
  Surface
   Pavement
           Well Screen
                           Free Product Layer
                          Product/Water Contact
                                           _J
Perimeter of Tank
  Excavation
       Monitoring wells installed in the excavation
       zone will quickly detect a release when the
       ground water table is within the tank
       excavation.

-------
              SLIDE IV-48

THE WELL SCREEN IS PLACED TO EXTEND
   OVER THE ENTIRE RANGE OF WATER
          TABLE FLUCTUATION
    SCREENED RANG!  • -
                          OftOUNO SURFACE
                      High Water Table
                        HANOI OP WATIMTAftLI
                          FLUCTUATION
                     Low Water Table

-------
                 SLIDE IV-49

             MONITORING WELLS
In manual systems, ground-water samples must
be collected from the well by hand with a bailer at
least once a month

In automatic systems, the detector operates by
itself and sounds an alarm.  This system is used
at least once per month

-------
                    SLIDE IV-50



     HOW GROUND-WATER MONITORING WORKS





Manual Devices



•  Grab samplers



•  Chemical-sensitive pastes

-------
                     SLIDE IV-51
     HOW GROUND-WATER MONITORING WORKS

Types of automatic devices
•  Differential float devices
•  Product soluble devices
•  Thermal conductivity devices
•  Electrical conductivity devices

-------
              SLIDE IV-52


  SCHEMATIC OF A DIFFERENTIAL

            FLOAT DEVICE
                                   Monitor
Reinforced Concrete Slab
    Over Tank
                     Bottom Alignment Spacer
             X
  Top Alignment Spacer
 Monitoring Wefl
                  Bottom Locking Nut

-------
            SLIDE IV-53

 SCHEMATIC OF A MECHANICALLY
       ACTIVATED PRODUCT
         SOLUBLE DEVICE
Ground Surface
                   Spring Loaded Indicator
                   Monitoring '/,
 ^Groundwaterx
 glablc

-------
      SLIDE IV-54

SCHEMATIC OF THERMAL
 CONDUCTIVITY DEVICE
Monftodnf Wtil -».

-------
                    SLIDE IV-55

WHEN GROUND-WATER MONITORING IS APPROPRIATE


UST system characteristics

•  Can be used to detect leaks from both tanks and
   pipes

•  May be used on any size tank. For larger systems,
   more wells are added

•  May be retrofitted

-------
                   SLIDE IV-56
WHEN GROUND-WATER MONITORING IS APPROPRIATE
Product characteristics
•  Density must be lower than that of water
•  Product should not mix easily with water
•  Two examples are gasoline and diesel fuel

-------
                    SLIDE IV-57

WHEN GROUND-WATER MONITORING IS APPROPRIATE


Soil conditions

•  Soil or backfill between well and UST must be
   permeable

•  Soil or backfill must be porous enough to allow
   released product to travel to wells

•  Hydraulic conductivity should  be > 0.01 cm/sec

-------
                    SLIDE IV-58

WHEN GROUND-WATER MONITORING IS APPROPRIATE
Climatic factors

•  Very low temperatures can cause incorrect test
   results. Ice can freeze monitors and interfere with
   product-soluble devices

-------
                    SLIDE IV-59
WHEN GROUND-WATER MONITORING IS APPROPRIATE

Geologic conditions
•  Level of ground-water table must be less than 20 feet
   from the surface
•  Fluctuations in water table level may restrict use
•  Gradient of ground-water flow must be known for
   effective placement of monitoring wells
•  Well placement must account for fractures and
   cavities in the soil

-------
            SLIDE IV-60

 POORLY PLACED GROUND-WATER
        MONITORING WELL
Product-Filtod
Fractures
           Not*: No Fre« Product in Well
Fractured Rock
Karstic Limestone

-------
                    SLIDE IV-61



                 CONSIDERATIONS





•  Site assessment is necessary



•  Operation of detection devices is simple



•  Avoid damage to tanks and pipes during installation

-------
                SLIDE IV-62

  HOW VAPOR MONITORING SYSTEMS WORK
Check for presence of product fumes near UST
system

Automatic systems incorporate network of sensors

Manual systems use air samples collected from a
network of wells

-------
                 SLIDE IV-64

UNDERGROUND STORAGE TANK SYSTEM WITH
         VAPOR MONITORING WELLS
         VAPOR
        MONTTORM4G
         DEVICE
 VAPOR
MOMTORMG
 WELL

-------
                 SLIDE IV-65

     MAP VIEW OF TYPICAL UST SITE
        WITH VAPOR MONITORING
                  PUMP
PUMP
                                  PUMP
  VAPOR WELL IN
PRODUCT LINE BACKFILL
      PRODUCT LINES
  BACKGROUND VAPOR WELL
               VAKMWEU.
              MTANKSACKnU.
                                 /  10* RADIUS OF
                                / INFLUENCE FOR WELLS

-------
                    SLIDE IV-66

    WHEN VAPOR MONITORING IS APPROPRIATE


UST system characteristics

•  Can be used for both tanks and piping

•  Can be installed with new or existing tanks and
   piping

-------
                    SLIDE IV-67
    WHEN VAPOR MONITORING IS APPROPRIATE
Product characteristics

•  Must be used with products that vaporize readily
   (e.g., gasoline)

-------
                    SLIDE IV-68

    WHEN VAPOR MONITORING IS APPROPRIATE
Soil conditions

•  Backfill around tank must allow the passage of
   vapors

•  Soil should be clean and should not contain
   substances that will produce vapors

-------
           SLIDE IV-69

THE EFFECT OF SOIL ON VAPOR
 CONCENTRATIONS AT A WELL
 8000
 6000 -
I

I
 uooo -
 2000-
                            Dry gravel backfill
Dry sIKy sand
Moist sand backfill
                            Wet sand or clay
            10       20
             Number of Days

-------
                    SLIDE IV-70

     WHEN VAPOR MONITORING IS APPROPRIATE


Climatic factors

•  Temperature affects the volatility of released product

•  This method should not be used in areas with heavy
   annual rainfall or extremely moist climates

•  Water fills spaces between soil particles

•  Vapors may dissolve in the moisture

•  Heavy rains may fill wells with water and drown
   sensors if not properly capped and sealed

-------
                    SLIDE IV-71

    WHEN VAPOR MONITORING IS APPROPRIATE


Geologic conditions

•  This method should not be used in areas with high
   groundwater, which interferes with vapor detection

-------
                 SLIDE IV-72
              CONSIDERATIONS
Manual monitoring systems require monthly time
investments
--  Large sites require considerable time each month
--  Samples are often sent off-site for analysis
Spill/overfill protection needed

-------
                  SLIDE IV-73A

               HOW SIR  WORKS

Daily measurements of product level in tank combined
with complete records of all withdrawals from the UST
and deliveries to the UST

SIR vendor uses sophisticated statistical software to
conduct computerized analysis of data

SIR vendor provides monthly reports that can identify if
UST is leaking

-------
                   SLIDE IV-73B

                 HOW SIR WORKS

SIR must be done monthly and meet the PD/PFA and
minimum detectable leak rate (0.2 gallons per hour)

Monthly SIR results must be available at the UST facility

SIR can qualify as a tank tightness test if it meets Federal
requirements for PD/PFA and minimum detectable leak rate
(0.1 gallons per hour)

-------
                   SLIDE IV-73C

            WHEN SIR IS APPROPRIATE

UST system characteristics

-   Primarily used for tanks with capacity less than
    18,000 gallons

Product characteristics

-   Generally not restricted by product type

Soil conditions

--   No restrictions exist

-------
                  SLIDE IV-73D

           WHEN SIR IS APPROPRIATE

Climatic factors

--  Temperature changes affect data, so SIR vendors must
   take climatic factors into consideration

Geologic conditions

--  Ground water covering all or part of a tank may mask a
   leak or distort the data

-------
                 SLIDE IV-73E

               CONSIDERATIONS

SIR can be used for tank and piping

SIR is a very sophisticated statistical analysis that must
meet Federal requirements

SIR requires the use of good inventory measurement
practices

-------
                   SLIDE IV-73F

                CONSIDERATIONS

Data can be sent to SIR vendor on paper or using computer
modems or diskettes

SIR can identify leaking systems, miscalibrated meters,
tilted tanks, and loss resulting from theft

SIR requires minimal investment of staff time and
equipment costs; overall costs compare favorably to other
methods

State and local governments can place restrictions on SIR
use

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                 SLIDE IV-74

           COMBINATION METHOD
Inventory control must be combined with tank
tightness testing

This combined method can be used only for ten
years following new tank installation or existing tank
upgrade

-------
                    SLIDE IV-75

               INVENTORY CONTROL


How inventory control works

•  Daily accounting system is used

•  Tank volume, deliveries, and sales are recorded daily

•  Accounts of deliveries and product sold from tank are
   compared with daily volume measurements

•  Overage/shortage determined monthly

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                    SLIDE IV-76

         HOW INVENTORY CONTROL WORKS


Daily tank gauging and reconciling

•  Measure product level with a gauge stick marked to
   one-eighth of an inch

•  Translate level of product from gauge to volume of
   product in tank, using manufacturer calibration chart

•  Record product volume and day's withdrawals and
   receipts on ledger form

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                 SLIDE IV-77

      HOW INVENTORY CONTROL WORKS
Gauge stick must be inserted through fill pipe until it
touches bottom of tank

-------
SLIDE IV-78
SAMPLE CALIBRATION CHART CONVERTING PRODUCT
DEPTH TO GALLONS*

^\Tank Size
Deptn^-x^
in Inches ^x^
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
550 Gal.
49V2" x 5'5"
2
7
13
20
29
37
47
57
68
79
90
102
115
127
140
1000 Gal.
491/2"x 10'
4
13
24
38
52
68
86
104
124
144
165
187
209
232
255
1000 Gal.
64" x 6'
3
9
17
26
36
47
59
72
85
100
114
130
145
162
178
1500 Gal.
64" x 9'
4
13
25
39
54
71
89
108
128
150
172
195
218
243
268
2000 Gal.
64" x 12'
6
18
34
52
75
94
119
144
171
200
229
260
291
324
357
2500 Gal.
64" x 15'
8
23
42
65
90
118
148
180
214
250
287
325
364
495
447
3000 Gal.
64"x^8'
9
27
51
78
108
142
178
217
257
300
344
390
437
486
536
4000 Gal.
64" x 24'
13
37
68
104
145
189
238
289
343
400
459
520
583
648
715
* Note that product depth in left column converts to^albns in the other columns.


-------
               SLIDE IV-79
         PART OF A MONTHLY
        RECONCILIATION FORM
LINE































1
2
3
4
DAY
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Cum. Over Total
% Thru.
Cum. Short. Total
% Thru.
REGULAR



































UNLEADED



































Attention: The cumulative sum of monthly overages or shortages should not exceed
     1.0% of the monthly throughput plus 130 gallons.

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                    SLIDE IV-80

            MONTHLY RECONCILIATION
              (INVENTORY CONTROL)
Monthly reconciliation

•  At least monthly, daily product volume data are
   reconciled with delivery and withdrawal amounts

•  If overage/shortage is greater than or equal to 1.0
   percent of tank's flow-through volume plus 130
   gallons of product, UST may be leaking

   --  If this occurs over two consecutive months,
      owner/operator must report results to local
      implementing agency as possible leak

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                    SLIDE IV-81

         HOW INVENTORY CONTROL WORKS


Tank stock control

•  Dispensing meters must be correctly calibrated

•  Product delivery volumes must be verified

•  Unaccounted for additions and withdrawals must be
   included in reconciliation

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                 SLIDE IV-82

       GENERAL PROCEDURE FOR
           INVENTORY CONTROL
Testing
Analysis
                    Tank Gauging
                           Product gauge
                           Water gauge
                     Calibration
       Volume of product determined
       from calibration chart
                  Tank Stock Control
                           Withdrawals
                           Receipts
                Recording & Reconciliation
Interpretation
Leak

No Leak

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                    SLIDE IV-83

    WHEN INVENTORY CONTROL IS APPROPRIATE


UST system characteristics

•  Applicable for any size UST as long as performance
   standard of 1.0 percent flow-through plus 130 gallons
   is met

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                    SLIDE IV-84
    WHEN INVENTORY CONTROL IS APPROPRIATE
Product characteristics
•  Effective for diesel and gasoline fuels and products
   with similar viscosities and thermal properties
•  For other products, make sure this method can be
   used satisfactorily with those substances
Soil conditions
•  Are not a factor

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                    SLIDE IV-85

    WHEN INVENTORY CONTROL IS APPROPRIATE


Climatic factors

•  Ambient air and ground temperatures can affect
   measured product volume

•  Temperature difference between newly-delivered
   product and product in tank limits accuracy

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                    SLIDE IV-86

    WHEN INVENTORY CONTROL IS APPROPRIATE
Geologic conditions

•  High ground water may interfere with testing

   --  This method may be inappropriate for areas with
      permanent high ground water

•  Monthly measurement using a gauge covered with
   water-finding paste must be taken to identify any
   water in tank, and accounted for in reconciliation

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                 SLIDE IV-87

              CONSIDERATIONS


Must be combined with periodic tank tightness tests

Regular calibrations and calculations

Staff time

Small leaks can go undetected for a long period

Used only with metered storage tanks

Deliveries  made through drop tube extending to
within one foot of tank's bottom

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                    SLIDE IV-89



FACTORS AFFECTING INVENTORY CONTROL RESULTS





•  Temperature variation



•  Meter calibration accuracy



•  Tank volume/calibration chart discrepancy



•  Delivery overage or shortage



•  Theft



*  Tank tilt

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                 SLIDE IV-91



   HOW TANK TIGHTNESS TESTING WORKS





Identifies leaks in closed tank systems



--  Volumetric tests



--  Non-volumetric tests

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                    SLIDE IV-92

       HOW TANK TIGHTNESS TESTING WORKS
Volumetric Testing

•  Changes in product level or volume in tank are
   measured precisely (in milliliters or thousandths of an
   inch) over several hours

•  Changes in product temperature must also be
   measured to account for temperature-induced
   changes in product level

•  Net decrease in product volume during test indicates
   leak

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           SLIDE IV-93
TEMPERATURE AND LEVEL GAUGES
                       TEMPERATURE
         LEVEL

-------
                        SLIDE IV-95
            COMPARISON OF PARTIALLY-FILLED
                  AND OVERFILLED TANKS
    Partially-Filled Tank
    Overfilled Tank
Large volume changes produce
only very small level changes
A small volume change can
produce a drastic level change

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                    SLIDE IV-96

       HOW TANK TIGHTNESS TESTING WORKS
Non-volumetric testing

•  Negative pressure (vacuum) is placed in tank.
   Equipment "listens" for small air bubbles

•  Tracers that will escape from a leak and be detected
   in the backfill can be added to the product

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                          SLIDE IV-97

          HOW TEMPERATURE CHANGES CAN BE
                    MISTAKEN FOR A LEAK
            CAP
                    CONCRETE
                                              CAP
                      CONCRETE
     PRODUCT LEVEL
                         FILL TUBE   PRODUCT LEVEL
           NEW, COOLER PRODUCT
              OLD PRODUCT
(A)  A tank has just had additional
    product added.
                     FILL TUBE
                                      MIXED, STABILIZED PRODUCT
(B)  After several hours, product
    mixture has stabilized
    temperature, resulting in lower
    product level.

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                     SLIDE IV-98

HOW STRUCTURAL DEFORMATION OF THE TANK
          CAN BE MISTAKEN FOR A LEAK
  PRODUCT LEVEL
                      FILL TUBE
          PRODUCT
                               PRODUCT LEVEL
                  FILL TUBE
       PRODUCT
   (A) An empty underground tank has just
      been filled with product
(B) In response to the pressure and/or
   temperature of the product, the ends
   of the tank begin to deflect (structural
   deformation), and the level of the
   product goes down.

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                   SLIDE IV-99

WHEN TANK TIGHTNESS TESTING IS APPROPRIATE


 UST system characteristics

 -  Test tanks smaller than 15,000 gallons

 --  If system is automated, up to four tanks may be
     tested at one time

 --  Piping may be tested similarly

 Product characteristics

 -  Primarily used in tanks containing gasoline,
     diesel, and light heating oils

-------
                  SLIDE IV-100

WHEN TANK TIGHTNESS TESTING IS APPROPRIATE


 Soil conditions

 -- Uncompacted backfill causes tank end deflection

 Climatic factors

 - Volumetric testing requires stable product
    temperature

 Geologic conditions

 -- Ground water level must be determined
 - Presence of ground water may mask an actual
    leak

-------
                 SLIDE IV-101



              CONSIDERATIONS





Must be used with inventory control



Tank must be taken out of service during test



Permanent installation of equipment unnecessary



Many different commercial methods are available



Tester must follow proper testing methods

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                   SLIDE IV-102

   HOW DO I SELECT THE RIGHT LEAK DETECTION
          METHOD FOR A SPECIFIC UST?

Deadlines for compliance

Monthly leak detection

-  Automatic tank gauging
-  Manual tank gauging
-  Secondary containment with interstitial monitoring
--  Ground-water monitoring
--  Vapor monitoring
--  Statistical inventory reconciliation

Inventory control and tank tightness testing

-------
             CHAPTER V-1



LEAK DETECTION METHODS FOR UST PIPING

-------
                 SLIDE V-2
WHAT DO I NEED TO KNOW ABOUT UST PIPING
     MONITORING AND LEAK DETECTION?
UST piping
Leak detection requirements for UST piping
Leak detection methods

-------
                 SLIDE V-3



       PRESSURIZED PIPING SYSTEMS





Product is pushed through a pump in bottom of tank



Very large releases can occur quickly at a break



Systems are usually chosen for high volume sites

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                 SLIDE V-4

          SUCTION  PIPING SYSTEMS
A positive displacement pump creates a vacuum
which draws product from the tank to the pump

If a leak in the lines occurs, suction is interrupted,
and product flows back through the piping toward the
tank

-------
                   SLIDE V-5

AMERICAN AND EUROPEAN PIPING SYSTEMS WITH
                CHECK VALVES
     American System
European System
           •Check Valve

-------
                 SLIDE V-6
      LEAK DETECTION FOR UST PIPING
Deadlines
Requirements
Methods

-------
                 SLIDE V-7

       PRESSURIZED PIPING DEADLINES
New pressurized piping: must comply with UST leak
detection requirements when installed

Existing pressurized piping: must comply with UST
leak detection requirements by December 1990

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                  SLIDE V-8

         SUCTION PIPING DEADLINES
No leak detection is required for new or existing
"European" style piping

--  Adequate slope
--  One check valve

New "American" style suction piping must comply
with  UST leak detection requirements when installed

Existing "American" style suction piping must comply
with  UST leak detection requirements according to
the following timetable

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           SLIDE V-9
Installation         Must Comply
   Date                By
Before 1965*       December 1989
1965 -1969         December 1990
1970 -1974         December 1991
1975 -1979         December 1992
1980 -1988         December 1993
 Or if installation date is unknown

-------
         SLIDE V-10
PRESSURIZED PIPING SYSTEM
                Gas Pump Ga» Pu™P
         Line Leak
         Detector

-------
                     SLIDE V-11

     REQUIREMENTS FOR PRESSURIZED PIPING

Pressurized piping (new and existing)

•  Each pressurized piping run must have an automatic
   line leak detector (LLD)

•  Pressurized piping  must also have one of the
   following:

   --  Monthly ground-water monitoring

   --  Monthly vapor monitoring

   --  Monthly interstitial monitoring

   -  Annual tightness test

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                     SLIDEV-12

          SUCTION PIPING REQUIREMENTS


If new and existing suction piping requires leak detection,
then one of the following four methods must be used

•  Line tightness testing (every three years)

•  Ground-water monitoring

•  Vapor monitoring

•  Secondary containment with interstitial monitoring

-------
                 SLIDE V-13



     AUTOMATIC LINE LEAK DETECTORS





Automatic flow restrictor



Automatic shutoff device

-------
                 SLIDE V-14
         LEAK DETECTION METHODS
Automatic line leak detectors
Line tightness testing methods
Monthly monitoring methods

-------
                 SLIDE V-15

         REQUIREMENTS FOR PD/PFA
Line tightness testing must meet the requirements for
the probability of detection and false alarm (PD/PFA)
by December 1990

Automatic line leak detectors must meet the PD/PFA
requirements by September 1991

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                 SLIDE V-16

 HOW AUTOMATIC FLOW RESTRICTORS WORK
Mechanical devices installed directly in the piping or
pump housing

When pressure in the pump delivery system drops
below a certain threshold, a test is automatically
performed

Devices trigger an alarm when a leak is detected

-------
                 SLIDEV-17

 HOW AUTOMATIC FLOW RESTRICTORS WORK
Restrictors reduce flow of product when there is a
leak

Restrictors limit product flow to 3 gallons per hour

-------
                SLIDE V-18

          WHEN AUTOMATIC FLOW
       RESTRICTORS ARE APPROPRIATE
Use only for pressurized piping

Most gas station USTs already have automatic flow
restrictors

-------
                  SLIDEV-19

              CONSIDERATIONS
Causes slight lag in product delivery when properly
operating

On-site staff may tamper with system to avoid delays
in product delivery

Requires little owner/operator involvement

-------
                 SLIDE V-20

         AUTOMATIC FLOW SHUTOFF


Two different types of automatic flow shutoff
devices

--  Pressure increase monitor

--  Pressure decrease monitor

-------
                    SLIDE V-21

  HOW AUTOMATIC FLOW SHUTOFF DEVICES WORK


Pressure Increase Monitor

•  Normal rate of pressurization in pipes is calculated

•  The rate of increase in line pressure is measured
   when pump is activated

•  If there is a leak, it will take longer for the piping to
   become fully pressurized

•  The system shuts down  automatically

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                    SLIDE V-22
  HOW AUTOMATIC FLOW SHUTOFF DEVICES WORK

Pressure Decrease Monitor
•  System monitors line pressure over several minutes
   when dispenser is not in use
•  A leak is indicated if:
   --  Constant pressure can not be maintained
   --  Pressure decreases more  quickly than its normal
      rate

-------
                SLIDE V-23



 WHEN SHUTOFF DEVICES ARE APPROPRIATE





Used for pressurized piping only

-------
                 SLIDE V-24

              CONSIDERATIONS
Devices are subject to tampering if they are not
locked or tamper-proofed in some way

Test cannot be run while dispensers are in use

Devices provide nearly continuous leak detection and
require little time from staff

-------
                  SLIDE V-25



          LINE TIGHTNESS TESTING





Direct volumetric line tightness test



Indirect line tightness test

-------
                 SLIDE V-26

     HOW THE DIRECT VOLUMETRIC LINE
          TIGHTNESS TEST WORKS
Tests the ability of UST piping to maintain a specified
pressure

A hand pump or the dispenser and the submerged
pump is used to pressurize the piping leading back to
the tank

The amount of volume lost is determined

If a certain volume of product is lost, a leak is
indicated

-------
                 SLIDE V-27

       WHEN THE DIRECT VOLUMETRIC
    LINE TIGHTNESS TEST IS APPROPRIATE
It is practical when performed in conjunction with
tank testing

Line tightness testing may be performed on both
pressurized and suction systems

-------
                 SLIDE V-28

              CONSIDERATIONS


Line must be shut down for several hours for the test

Test requires no permanent equipment

Test can conveniently be performed along with tank
tightness testing

Test needs to be  performed only once every three
years for suction  piping

Problems are due to poor fittings and gaskets, vapor
pockets, bad check valves, etc.

-------
                   SLIDE V-29

HOW THE INDIRECT LINE TIGHTNESS TEST WORKS


 Piping is tested as a part of a full tank system test

 Procedures are the same as for tank tightness with
 the following additions:

 --  Overfill methods must be used

 --  If test finds no leaks, both tank and lines are
    assumed to be intact

 --  If tank is leaking, separate test of piping must be
    conducted

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                 SLIDE V-30

          WHEN THE INDIRECT LINE
      TIGHTNESS TEST IS APPROPRIATE
Indirect line tightness tests must be done in
conjunction with tank testing; tanks and piping may
be on different test schedules

Line tightness testing may be performed on both
pressurized and suction systems

-------
                  SLIDE V-31

              CONSIDERATIONS


Lines must be shut down for at least several hours

Test must be performed only once every three years
for suction piping (annually for pressurized piping)

After filling the line, tester should wait for three hours
before beginning data collection

Vapor pockets can inhibit effective testing

-------
                 SLIDE V-32

      SECONDARY CONTAINMENT WITH
          INTERSTITIAL MONITORING
Methods, considerations, and applications of
interstitial monitoring with secondary containment for
piping systems are similar to those for tanks

Use trench liners or double-walled piping

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                     SLIDE V-33

 HOW SECONDARY CONTAINMENT WITH INTERSTITIAL
                MONITORING WORKS
For trench liners

•  Backfill and piping are placed in a lined trench

•  Trench should be sloped away from the tank
   excavation to differentiate between tank leaks and
   piping leaks

•  An interstitial  monitor is placed between piping and
   the trench liner

-------
                    SLIDE V-34

 HOW SECONDARY CONTAINMENT WITH INTERSTITIAL
               MONITORING WORKS
For double-walled piping

•  Piping that carries the product is contained within a
   larger outer pipe

•  Monitor is placed in sump or between inner and outer
   pipes

-------
                    SLIDE V-35
      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
UST system characteristics
•  Can be used for both tanks and piping
•  Secondary containment is not practical for existing
   piping

-------
                    SLIDE V-36
      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
Product characteristics
•  Methods may be used for all fuel types, including
   hazardous substances
Soil conditions
•  No restrictions exist

-------
                    SLIDE V-37

      WHEN SECONDARY CONTAINMENT WITH
     INTERSTITIAL MONITORING IS APPROPRIATE
Climatic factors

•  No restrictions.  However, in areas with heavy rainfall
   a fully enclosed  containment system should be used

Geologic conditions

•  In areas of high  ground water, a fully enclosed
   containment system should be used

-------
                  SLIDE V-38

              CONSIDERATIONS


Correct installation is essential

Monitoring can often be integrated with the tank
monitoring system

Prevents environmental contamination and reduces
potential for cleanup costs

-------
                    SLIDE V-39

           GROUND-WATER MONITORING


How does ground-water monitoring work?

•  Use of this method for piping is generally the same
   as its use for tanks

•  Additional wells are needed every 10 to 20 feet of
   piping run

-------
                    SLIDE V-40
WHEN GROUND-WATER MONITORING IS APPROPRIATE

UST system characteristics
•  Ground-water monitoring can be used to detect leaks
   from both tanks and piping
•  Ground-water monitoring may be used on any
   size piping run. For larger systems, more wells
   are added
•  May be retrofitted on existing tanks and piping

-------
                    SLIDE V-41



WHEN GROUND-WATER MONITORING IS APPROPRIATE





Product characteristics



•  Density must be lower than that of water



•  Product should not mix easily with water



•  Two examples are gasoline and diesel fuel

-------
                    SLIDE V-42
WHEN GROUND-WATER MONITORING IS APPROPRIATE
Soil conditions
•  Backfill between well and LIST must be permeable
•  Soil or backfill must be porous enough to allow
   released product to travel to wells
•  Hydraulic conductivity should be more than 0.01
   cm/sec

-------
                     SLIDE V-43

WHEN GROUND-WATER MONITORING IS APPROPRIATE


Climatic factors

•  Very low temperatures may interfere.  Ice can freeze
   monitors and interfere with product-soluble devices

-------
                    SLIDE V-44

WHEN GROUND-WATER MONITORING IS APPROPRIATE


Geologic conditions

•  Level of ground-water table must be no more than 20
   feet below the surface

•  Fluctuations in water table level must be taken into
   account

•  Gradient of ground-water flow must be taken into
   account

-------
               SLIDE V-45

     CREVICES AND FRACTURES
Product-Filled
Fractures
     V
        Water-Filled
        Fractures
               Note: No Free Product in Well
Fractured Rock
Karstic Limestone

-------
                 SLIDE V-46

              CONSIDERATIONS


Site hydrogeological assessment is needed

Operation of detection devices is simple

Can be integrated with tank ground-water monitoring
system

Avoid damage to pipes during installation

-------
                 SLIDE V-47

             VAPOR MONITORING
Use of this method for piping is generally the same
as its use for tanks

Wells used for piping monitoring can be shallower
than those used for tank monitoring

-------
                    SLIDE V-48
    WHEN VAPOR MONITORING IS APPROPRIATE
UST system characteristics
•  Can be used for both tanks and piping
•  Can be installed with new or existing tanks and
   piping

-------
                    SLIDE V-49

    WHEN VAPOR MONITORING IS APPROPRIATE


Product characteristics

•  Vapor monitoring must be used with products that
   vaporize readily (e.g., gasoline)

-------
                    SLIDE V-50

    WHEN VAPOR MONITORING IS APPROPRIATE
Soil conditions

•  Backfill around tank must allow the passage of
   vapors

•  Soil must be clean and should not contain
   substances that will produce vapors

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               SLIDE V-51


  THE EFFECT OF SOIL CONDITIONS ON
  VAPOR CONCENTRATIONS AT A WELL
 8000
 6000 -
Q.
a.

c
&
15
£4000
o
O

-------
                    SLIDE V-52
    WHEN VAPOR MONITORING IS APPROPRIATE

Climatic factors
•  Temperature affects the volatility of released product

-------
                     SLIDE V-53
     WHEN VAPOR MONITORING IS APPROPRIATE
Geologic conditions
•  This method cannot be used in areas with high
   ground water, which interferes with vapor detection
•  Water fills spaces between soil particles

-------
                 SLIDE V-54

             CONSIDERATIONS
Can easily be integrated with tank vapor monitoring
system

-------
                   SLIDE V-55

               HOW SIR WORKS

Daily measurements of product level in tank combined
with complete records of all withdrawals from the LIST
and deliveries to the UST

SIR vendor uses sophisticated statistical software to
conduct computerized analysis of data

SIR vendor provides monthly reports that can identify if
UST is leaking

SIR must be done monthly and meet the PD/PFA and
minimum detectable leak rate (0.2 gallons per hour)

Monthly SIR results must be available at the UST facility

-------
                         SLIDE V-56

               WHEN SIR  IS APPROPRIATE
UST system characteristics
    Requires daily measurements
Product characteristics
    Generally not restricted by product type
Soil conditions
    No restrictions
Climatic factors
    Temperature changes affect data, so SIR vendors must take climatic
    factors into consideration
Geologic conditions
    SIR for piping is not affected by geologic conditions

-------
                  SLIDE V-57

               CONSIDERATIONS

SIR can be used for tank and piping

SIR is a very sophisticated statistical analysis that must
meet Federal requirements

SIR requires the use of good inventory measurement
practices

-------
                    SLIDE V-58

                 CONSIDERATIONS

Data can be sent to SIR vendor on paper or using computer
modems or diskettes

SIR can identify leaking systems, miscalibrated meters, tilted
tanks, and loss resulting from theft

SIR requires minimal investment of staff time and equipment
costs; overall costs compare favorably to other methods

State and local governments can place restrictions on SIR
use

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               SLIDE V-59

WHAT DO I NEED TO KNOW ABOUT UST PIPING
    MONITORING AND LEAK DETECTION?

 UST Piping

 Leak Detection for UST Piping

 Leak Detection Methods

-------