Case Study and Recommendations

for
ATM Tank and Line Testing.
€ Client
– State Highway Authority owns
service stations, leases to private
operator

€ Synergy
Environmental - consultant
managing UST compliance

€ Clientprovides weekly ATG information

via printout for compliance reporting
€ Saturdaymorning,
morning 8 AM,
AM operator
reconciles inventory with sales and notes
a 1500 gallon discrepancy.
discrepancy

€ Operator notifies Synergy for technical

assistance
€ Tanksare Double wall- are interstitial
sensors alarming? – NO
• tanks are not leaking
€ Line Leak testing- any alarms? - NO
• currently passing 3.0 gph all lines
€ Weekend sales clerk math error /other
shenanigans? - NO
€ Conclusion – would need to visit site to
troubleshoot. (ATM is not connected via
modem to acquire data )
€ Stick tank and Suspend Sales?
€ for what duration - 1/8” measurement per
50 gallons
€ Double wall sensors don’t indicate a
problem,
bl client
li d
doesn’t
’ want to llose sales.
l
€ If s utdow required,
shutdown equ ed, must
ust notify
ot y authority
aut o ty –
major consequences will ensue
€ Continue operations

€ Checkfuel levels in 24 hours – standard

reconciliation

€ Red
Sox at Yankees – Yanks on run to
championship
€ Clientreports additional 1200 regular
gasoline loss- now total suspected loss at
2700 gallons

€ ATM still indicates no alarms

€ Client directed by Synergy to stop all

sales
€ Sales
clerk to stick tanks every 30
minutes and report back results

€ Clientto notify Regulatory agency to

report a suspected loss

€ Yanks have gained another game on the

Sox
€ Onsite
review confirms release and
evidence of undisclosed adjacent site
remediation underway
€ 12
foot deep excavation discovered, 15 feet
away from dispenser area.
€ Gasolineaccumulated in tank top sump at
UST furthest
US u t est distance
d sta ce from
o dispensers
d spe se s
€ Client
has transporter removing product
from UST
€ Two days before – Highway Authority
(tank system owner) had a certified
contractor sever and terminate three
gasoline lines and one diesel lines.

€ Contractortested modified lines - 50 PSI

nitrogen for only 15 minutes – should
have been tested for 1 hour
€ After test Contractor purged the nitrogen

€ Reintroduced motor fuels in the lines

€ Sales resumed

€ Obviouslysomething went wrong during

piping reconstruction
€ 20minutes after dispense to complete a 3.0
30
gph test

€ 40 minutes after the 3.0 gph test- complete a

0.2 gp
gph test

€ 60 minutes after the 0.2 gph test, complete a

0.1 gph test.
To perform all three tests, a 2 hour shutdown is required
€ Highway
Hi h Service
S i Plazas
Pl are problematic
bl ti
because they are busy – minimal idle time

€ This
location has only one regular gasoline
UST piped to the most active two dispensers

€ Minimal idle time means limited

opportunity for successful 3.0 gph test
((needs 20 minutes uninterrupted)
p )
€ Contractor nitrogen test insufficient
length of time.

€ Significant
pipe length removed, but ATG
parameters not modified

€ PipeLength affects leak detection

sensitivity.
Review of 3.0
3 0 gph tests indicate the line
was still passing after the 1200 gallon
inventory discrepancy

Review of the 00.2

2 gph tests indicate very
infrequent performance of test due to
high traffic at service station
€ 50psi nitrogen line test weakened a
piping tee connection

€ Productwas releasing during 26 PSI

dispensing
€ The length of piping in the ATG setup
parameters was never reduced after pipe
alteration

€ *** Thispermitted the test duration to be

set short of the required time period

€ Passing
P i result
lt ffor th
the 3
3.0
0 gph
h ttestt lleak
k
rate not severe enough to drop pressure
below the 12 psi alarm level
€ No number of facilities inspection would
have discovered the piping flaw
€ The piping length in the ATM set up is
not reviewed during a facility inspection.
€ Functionality testing of the leak detector
would not have revealed this leak
€ *** Operator training (Class A,A B and C)
does not evaluate technical aspects of
leak detectors
€ Third Party remotely monitors the ATG
• Force tests remotely
• Diagnostic modes can be reviewed in real time

€ High
g volume
o e locations
oc o are e vulnerable
e e to
o
technology limitations
• Require
q a 0.2 gp
gph test daily
y instead of monthly
y
• Require a 0.1 gph test monthly instead of yearly
€ UST insurers and State Fund Administrators
should handle high volume locations with
different parameters:
• More frequent 0.2 gph tank and line testing
• Insurance premium discount for third party
monitoring
• Higher standard of care should be required in a
more technical facility inspection
€ Revisethe Client problem resolution
decision tree
• First line of response for significant discrepancies
should be a two hour shut down :
x Perform (remotely if possible) an ATG static test of at
least a 3.0 gph on the tanks
x Perform (remotely if possible) a 3.0, 0.2 and 0.1 gph ATG
test on the product lines