THE ENVIRONMENTAL TECHNOLOGY VERIFICATION
PROGRAM
oEPA
M-S. Ennramiifal Ptvtoction Agmty
Bameiie
The Business of Innovation
TECHNOLOGY TYPE: AUTOMATIC TANK GAUGING (ATG)
LEAK DETECTION SYSTEMS
APPLICATION:
UNDERGROUND STORAGE TANKS
TECHNOLOGY NAME: Phase-Two™ Water Detector
COMPANY:
ADDRESS:
WEB SITE:
E-MAIL:
Veeder-Root Company
125 Powder Forest Drive, P.O. Box 2003
Simsbury, CT 06070-7684 PHONE: 713-522-6300
http://www.veeder.com/
kreid@veeder.com
ETV Joint Verification Statement
The U.S. Environmental Protection Agency (EPA) has established the Environmental Technology Verification
(ETV) Program to facilitate the deployment of innovative or improved environmental technologies through
performance verification and dissemination of information. The goal of the ETV Program is to further
environmental protection by accelerating the acceptance and use of improved and cost-effective technologies.
ETV seeks to achieve this goal by providing high-quality, peer-reviewed data on technology performance to
those involved in the design, distribution, financing, permitting, purchase, and use of environmental
technologies. Information and ETV documents are available at www.epa.gov/etv.
ETV works in partnership with recognized standards and testing organizations, with stakeholder groups
(consisting of buyers, vendor organizations, and permitters), and with individual technology developers. The
program evaluates the performance of innovative technologies by developing test plans that are responsive to the
needs of stakeholders, conducting field and laboratory tests (as appropriate), collecting and analyzing data, and
preparing peer-reviewed reports. All evaluations are conducted according to rigorous quality assurance (QA)
protocols to ensure that data of known and adequate quality are generated and that the results are defensible.
The Advanced Monitoring Systems (AMS) Center, one of six verification centers under ETV, is operated by
Battelle in cooperation with EPA's National Risk Management Research Laboratory. The AMS Center recently
evaluated the Phase-Two™ Water Detector manufactured and distributed by Veeder-Root Company for its
ability to detect water ingress into an underground storage tank (UST) holding gasoline and gasoline/ethanol
blends. The technology vendor installed the equipment in a Battelle-designed/constructed test vessel and trained
Battelle staff on its proper use. Battelle staff conducted the evaluation.
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VERIFICATION TEST DESCRIPTION
Testing was performed between September 13 and September 30, 2011. The verification test was designed to
evaluate the functionality of the ATG systems when in ethanol-blended fuel service. The test was performed in
the interior of an existing research building (JS-20) at Battelle's West Jefferson, OH south campus. The building
interior and the exterior area surrounding the building were modified to accommodate a specially-fabricated test
vessel and support items. The test vessel was fabricated from a 6-ft diameter piece of a fiberglass storage tank
shell which was fitted with glass ends to allow visual observation of the conditions within the vessel during
testing. Exterior storage facilities were made available for fuel and waste storage.
The characteristics of independent variables were selected and established during the test runs to determine the
response of the dependent variables. Performance parameters were evaluated based on the responses of the
dependent variables and used to characterize the functionality of the ATG system. The water ingress tests were
focused on the mixing method of water addition into the test vessel. Three test designs were incorporated into the
evaluation:
• A continuous water ingress test consisting of two parts:
• Determination of minimum detection height;
• Determination of smallest detectable incremental change in height; and
• A quick water dump followed by a fuel dump.
In the first test, a continuous stream of water was introduced into the field test vessel to produce a splash on the
surface of the fuel or to not produce a splash by trickling the water along the surface of the fuel filler riser pipe to
slowly meet the surface of the fuel. The independent variables and levels for the continuous water ingress test
were:
• Fuel ethanol content (three levels): EO (no ethanol), E15 (15% ethanol), and flex fuel (up to 85% ethanol);
• Water ingress method/rate (two levels): with splash and without splash; and
• Fuel height (two levels): 25 % and 65 % full.
The water ingress method/rate was selected to establish conditions that impact the degree of mixing that occurs in
a tank using the three ethanol blends. The rate was established to accumulate enough water to generate a
technology response within 1 hour. If a response was not observed in 3 hours, the run was terminated.
Introducing water with a splash was accomplished by positioning a water tube such that water droplets would
free-fall to the fuel surface below. The test condition was maintained until a response in the water detection
technology was observed, or terminated after 3 hours if there was no response. Introducing water without a
splash was accomplished by positioning the water tube such that surface tension allowed the water to flow along
the outside of the fuel filler riser pipe with minimal agitation to the surface of the fuel. The test condition was
maintained until a response in the water detection technology was observed, or terminated after 3 hours if there
was no response.
Two fuel height levels were specified to establish different splash mixing regimes and diffusion columns. The
lower fuel height yielded the greater splash mixing potential, but the shorter diffusion columns through which the
water could flow. Conversely, the higher fuel height yielded the lower splash mixing potential, but the higher
diffusion column. The fill heights were established to ± 10% of the target height of either 25% or 65%. At 25%
and 65% of the height of the test vessel, 170 and 610 gallons of fuel, respectively, were in the test vessel.
To address the second part of the continuous water ingress test, once the water detection technology reacted to the
minimum water height, the smallest increment in water height that can be measured was determined. An ingress
rate of 200 mL/min was calculated to produce a height increase at the bottom of the tank of approximately l/16th
of an inch in 10 minutes. Readings were taken from the technology, as well as visually, 10 minutes after the
increment portion of the run started. Both the technology readings and the manually-measured water levels were
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recorded. Readings/measurements were taken after ten, 10-minute increments for each replicate of Test 1 (to
produce a minimum of 100 measurements).
The last type of test focused on the potential to detect phase separation in an UST. The test was designed to
simulate a quick water ingress rate followed by a high degree of mixing such as might occur if a large volume of
water was dumped into the tank at a 25% fill height and then fuel was dumped to fill the tank to a 65% fill height.
This test was mainly observational in that the test vessel was disturbed quickly with water and fuel, and the
response of the technology was recorded throughout the test. Three runs of this type were conducted, one for
each of the fuel types being evaluated in this verification test. The EO run was conducted first and used as the
baseline for the technology responses to establish the minimum wait time of 30 minutes with E15 and flex fuel.
Battelle staff checked the technology console for status messages continuously until an initial float response was
indicated, recorded several instrument parameter values at the time of initial float response and every 10 minutes
thereafter during the increment runs, and backed up the collected data each day. No on-site calibrations were
performed. Each time that the technology reading was recorded, an independent height measurement was taken
from the rulers installed on the glass ends or inside the test vessel.
QA oversight of verification testing was provided by Battelle and EPA. Battelle technical staff conducted a
performance evaluation audit, and Battelle QA staff conducted a technical systems audit and a data quality audit
of 25% of the test data. An independent technical systems audit was conducted on behalf of EPA. This
verification statement, the full report on which it is based, and the Quality Assurance Project Plan (QAPP) for
this verification test are available at www.epa.gov/etv.
TECHNOLOGY DESCRIPTION
The following information was supplied by the vendor and was not verified.
The Veeder-Root Phase-Two™ Water Detector is a concentric, dual-float system designed specifically for low-
ethanol blend gasoline up to E15. The float is installed at the bottom of a fuel storage tank and is used in
conjunction with a magnetostrictive level probe and ATG system. An inner float is designed to move freely
within the limits of a protective housing attached to the outer float to respond to all phase separation compositions
in these fuels. The outer float is ballasted to remain responsive to water and water-rich compositions of phase
separation. This allows the inner float to measure the full depth of water in the case of a massive ingress (lifting
both floats), while preventing the inner phase separation float from interfering with the fuel float in the rare
situation that an unusually dense, cold gasoline is delivered into the tank. As the detected phase separation depth
increases, the float rises and transmits an electronic signal proportional to the level of phase separation in the
bottom of the tank.
Information acquired during operation of the water detection technology was transmitted from the float via a
two-conductor signal cable to a data recording and display console. A single console can compile data for several
individual floats, and the Veeder-Root TLS-350 was used for this purpose during this verification test. The
TLS-350 provides an electronic display and paper printout of fuel and water heights and volumes, as well as
settings for warnings and alarms based on measured heights. The console also generates an electronic data file
that can be continuously transferred to a computer for users wanting access to the data.
VERIFICATION RESULTS
The Phase-Two™ Water Detector responded to the water ingress when the test fuel was EO and E15, but showed
no response when flex fuel was used as the test fuel. The float appeared to be neutrally buoyant in the flex
fuel/water mixture. The reason for the no response was that no clear separated dense phase was formed in the
flex fuel when water was added to the test vessel. As a result, the performance parameters defined in the QAPP
could not be determined for this technology when flex fuel was employed. The following table provides a
summary of verification test results for the Veeder-Root Phase-Two™ Water Detector; the calculated
performance parameters were determined using the pooled data from the EO and El5 water ingress runs.
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Currently 40 CFR, Section 280.43(a) states water detection technologies should detect "water at the bottom of the
tank," which does not address water entrained in the fuel due to increased miscibility with the presence of
ethanol. The water sensor, tested according to "EPA's Standard Test Procedures for Evaluating Leak Detection
Methods: Automatic Tank Gauging Systems," did not detect water in the test vessel containing either intermediate
(E15) or high (E85) ethanol blends if the water was suspended in the product or the water did not reach the
bottom of the tank. Because of this, there is not sufficient data to evaluate whether this technology, when used
with UST systems containing intermediate or high ethanol blends, would indicate a potential release under every
circumstance.
Performance
Parameter
Accuracy (EO and
El 5 only)
Sensitivity (EO and
El 5 only)
Precision (EO and
El 5 only)
Ease of use
Maintenance
Consumables/waste
generated
Method of
Evaluation
Comparison to manual
measurements
Comparison to manual
measurements
Evaluation of initial
response for all runs
with responses
Operator observations
Operator observations
Operator observations
Results
Bias -0.274 inches
Tolerance Limit 0.5 10 inches
Minimum Detectable Level nncco- i
_, 0.0558 inches
Change
Mean © 0.41 inches
Standard Deviation (SD) 0.035 inches
Precision (X/SD) 12
• Initial installation was completed in ~2 hours by vendor
• Operation is automated upon powering; requires no external intervention
• Operated unattended except for data downloads
• Daily comma-delimited data files are generated automatically and stored in
separate data files on an internal hard drive
• No routine maintenance activities were performed during testing
• The technology required no consumables and generated no waste
Signed by Tracy Stenner
9/26/12
Signed by Cynthia Sonich-Mullin
11/27/12
Date
Tracy Stenner
Manager
Environmental Solutions Product Line
Energy, Environment, and Materials Sciences
Battelle
Date
Cynthia Sonich-Mullin
Director
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
NOTICE: ETV verifications are based on an evaluation of technology performance under specific,
predetermined criteria and the appropriate quality assurance procedures. EPA and Battelle make no
expressed or implied warranties as to the performance of the technology and do not certify that a technology
will always operate as verified. The end user is solely responsible for complying with any and all applicable
federal, state, and local requirements. Mention of commercial product names does not imply endorsement.
EPA/600/R-12/731sl
December 2012
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