2015 national tanks conference compatibility “3...
TRANSCRIPT
2015 National Tanks ConferenceCompatibility “3rd Option”
Nate Blasing
September 15, 2015
Blender Pump
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New Federal UST Regulations 280.32
or Use another method determined by the implementing agency to be no less protective of human health and the environment than the compatibility demonstration methods listed above
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Current Regulations
MN Statute 239.791
Mandate for the highest percent biofuel authorized in a waiver granted by the EPA for all spark ignition motor vehicles (E15)
MN Statute 239.7911 Petroleum Replacement
14% by 2015
18% by 2017
25% by 2020
30% by 2025
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Current Regulations
MN Statute 239.77 Biodiesel Content
2% by September 29, 2005
5% by May 1, 2009
10% by May 1, 2014
20% by May 1, 2018
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E85 Facilities in Minnesota
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Timeline
July 2011 EPA compatibility guidanceFall 2011 the MPCA begins discussion on
enforcing compatibility requirementsSummer 2012 MPCA responds to four E85
releasesSeptember 2012 the MPCA mails compatibility
forms to 360 E85 facilitiesFall 2012 the MPCA begins discussions with
stakeholders on compatibility challenges
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Timeline
Winter 2013 the MPCA finds that NO E85 facilities in Minnesota are in 100% compliance with compatibility requirements
Summer 2013 the MPCA publishes factsheets on compatibility and the “3rd option”
Summer 2013 the MPCA holds a series of informational meetings across the Minnesota
2013-2015, facilities work towards installing compatible equipment
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Stakeholders
Minnesota Corn Growers AssociationRenewable Fuels AssociationGrowth EnergyMinnesota Biofuels AssociationEnergetixCentral Valley CooperativeSEH Inc.American Lung AssociationMinnesota Department of Agriculture
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Stakeholders
Holiday CompaniesKwik TripMinnesota Petroleum ServiceWestmor IndustriesPump & Meter ServiceMinnesota Petroleum Marketers AssociationMinnesota Service Station AssociationMinnesota Department of CommerceMinnesota Pollution Control Agency
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Concerns
Cost of upgrades for facilities Loss of facilities offering E85Why now, E85 has been available in
Minnesota since 1997What proof do you have that higher blends of
biofuels cause a problemPoliticsManufacturers that have closed, how do you
get a statement of compatibility (Equipment)
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MPCA “3rd Option”
MPCA developed a third, component specific option to demonstrate “compatibility”
3rd option is only available to facilities storing E85 prior to July 1, 2013
3rd option includes Increased visual inspections
Upgrade existing equipment
Installation of new compatible equipment
Integrity testing
Tightness testing
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Tanks & Piping
Tanks and piping
Must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Submersible Pump
Contained sumps – the tank owner and operator must conduct and document weekly visual inspections and perform a STP sump integrity test.
Dirt sumps – the tank owner and operator must install an AG pump O-ring package, as well as conduct and document weekly visual inspections.
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Automatic Tank Gauge
Single walled tanks – the tank owner and operator must conduct an annual tank tightness test as well as continue monthly tank leak detection tests.
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Automatic Tank Gauge
Double walled tanks (installed prior to December 22, 2007) – the tank owner and operator may decide to follow the option for single walled tanks for the first year. The tank owner and operator must use an interstitial sensor that is certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored no later than July 1, 2014.
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Automatic Tank Gauge
Double walled tanks (installed after December 22, 2007) – the tank owner and operator must use an interstitial sensor that is certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Overfill Equipment
Ball float, Alarm sensor, Automatic shutoff -must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Line Leak Detector
Dirt sumps – the line leak detector must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Line Leak Detector
Contained tank sumps with double walled piping – the tank owner and operator must conduct and document weekly visual inspections and perform a submersible sump tightness test.
Contained sumps with single walled piping follow dirt sump option.
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Sump Sensors
If the sump sensor is used to fulfill the line leak detection requirement the sump sensor must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Spill Buckets
Single walled spill bucket – the tank owner and operator must conduct and document weekly visual inspections and perform a spill bucket integrity test.
Double walled spill bucket – the tank owner and operator must conduct and document weekly visual inspections.
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Shear Valves
Must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Drop Tube
If the overfill equipment is a ball float or alarm sensor, then the existing drop tube can continue to be used.
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Drop Tube
If the overfill equipment is an automaticshutoff device, then the drop tube must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Vapor Recovery Equipment
Must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Dispenser Equipment
Contained sumps – the tank owner and operator must conduct and document weekly visual inspections and perform a dispenser sump integrity test.
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Dispenser Equipment
Dirt sumps – the tank owner and operator must conduct and document weekly visual inspections and must install a meter and manifold that is certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored no later than July 1, 2014.
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Dispenser Equipment
The meter and manifold must be changed to equipment that is certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored if the meter and manifold is damaged or fails to operate properly (fails to operate properly includes leaks but does not include calibration).
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Additional Components
UST system components not included in the component specific option must be certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
Includes hanging hardware
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Repair or Replace Equipment
UST system components that fail or are operating incorrectly must be repaired or replaced with equipment that is certified or listed by a nationally recognized, independent testing laboratory for use with the fuel stored or approved by the manufacturer to be compatible with the fuel stored.
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Lessons
Facilities do not know what equipment they have
MPCA did not have detailed records of what equipment was installed
Equipment is corroded, dirty and buried so determining manufacturer and model is difficult if not impossible
Contractors are not knowledgeable about compatibility
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Lessons
Require and enforce compatibility from day 1More than one method of determining
compatibility can get confusing for owners/contractors/regulators
Most facilities needed multiple attempts to complete the compatibility form
Need an outside source to fund the upgrades
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Questions
Nate BlasingSupervisor, Tanks Compliance UnitMinnesota Pollution Control Agency7678 College Road, Suite 105Brainerd, MN [email protected]
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