Forecourt
May/June 2003


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Leak Detection - it's now or … now

Y

ou can't say you were not warned. Two years ago we wrote, "No-one who wants to stay in business can afford not to look at continuous leak detection: Monitoring will be regulated in the years ahead, so it is false economy and short-term planning to think you can do without it. Do it properly. Now, it's time to say, "We told you so."

At best, only one-third of service stations nationally operate with an acceptable UPSS (underground petroleum storage system) monitoring system. An acceptable monitoring system is one that results in compliance with a raft of regulations in respect of dangerous goods and environment protection, and one that meets the standards set out in the new EPA Victoria Guidelines.

"The current level of compliance is low," says Reed Leighton, Director, Leighton O'Brien. "Basically, only the company-owned sites of most of the major networks have adequate systems. Most of the independents and smaller chains do not comply."

The Guidelines
With the release of the EPA Victoria's "Guidelines on the Design, Installation and Management Requirements for Underground Petroleum Storage Systems (UPSS) in February 2003, we entered a new era. Even though the Guidelines are not new regulations, they are a clear statement of how to comply with existing regulations. "The key message is to understand your obligations and use the Guidelines to meet those obligations," says Doug Ahearne, Environment Protection Officer, EPA Victoria. "Owners, occupiers and operators of UPSS are expected to implement the measures, or be able to demonstrate that their approach achieves the same or better in relation to protection of people, property and environment. It is not a regulation but a set of performance standards that will assist in complying with existing regulations. For example, under the Environment Protection Act, you must take all practicable measures to protect groundwater, and the Guidelines spell out those practicable actions."

Now that the EPA Victoria has spelled it out you better comply. And, if you are operating in another State, it's no good thinking they only apply to Victoria. "The other states are watching very closely and the Guidelines are likely to be rubber-stamped nationally," says John Beard, National President, PICA. "There may be some variations, such as in Queensland to meet requirements of city councils, but these are likely to be more, not less, stringent." Reed Leighton agrees: "They are really national requirements through the legal mechanism of the State and Territory dangerous goods acts that refer to the Australian Standard 1940, which in turn links to the revised AIP code, CP4."

The diagram above is extracted from the EPA Victoria Information Bulletin, and is reproduced here to assist in understanding the requirements. However, both the diagram and the material here are simplifications of the underlying requirements. So, you should get a copy of the Bulletin and the Guidelines, and talk to the experts listed at the end of this article.

Focusing on existing sites, Victorian owners of underground petroleum storage systems have until February 2004 to implement an approved leak detection system, and until February 2005 to determine if they own a "sensitive site".

The minimum requirement for all UPSS is a leak detection system that is rated to detect a release of 18 litres per day from the tanks and pipework, is verified by a 3rd party using USA EPA protocols, and reports at least once a month. Basically this means either Statistical Inventory Reconciliation Analysis (SIRA) or Automatic Tank Gauging plus Line Leak Detection.

SIRA
Only two companies undertake SIRA in Australia - Gilbarco Veeder-Root and Leighton O'Brien. "Leak detection used to be an AIP recommendation, now it's an EPA requirement," says Russell Dupuy, Environmental Marketing Manager Australasia, Gilbarco Veeder-Root. "Being based on reconciliation of inventory data (daily volumes, sales and deliveries), SIRA is a low-cost system that leverages every-day activities. However, it will require a minimum of 45 days of quality data to provide conclusive results and the success of conclusive SIRA output needs to be underpinned by sound inventory management at a site manager and operator level."

The SIRA system records all losses, including inaccurate dispensers, accounting errors, theft, and vapour loss. "Under SIRA, the data is processed through an EPA-approved protocol," says Reed Leighton. "If the report shows a loss, a number of simple checks are undertaken first. Less than 5% of systems showing losses need to have the tanks and lines tested for leaks. And, it is not necessarily old tanks that fail. It can depend on quality of installation."

"Manual inventory control by tank dipping also raises the issue of who will do the dips, especially when there is only one person on-site," adds John Beard, also Manager-Petroleum, Treloar Group Pty. Limited.

Automatic Tank Gauging
For these and other reasons, the major oil companies are increasingly using automatic tank gauges as a method of more accurate, repeatable and reliable means of tank volume measurement that includes automatic delivery detection with temperature and water measurement. Options range from simple tank gauges (reporting tank volumes, water present and temperature) to sophisticated wet-stock management systems, complete with alarms and automatic shut-down options, integrated with POS and accounting systems that do all the work for you in real-time. The more sophisticated systems continuously monitor tanks and lines while the site is operating, and include precision inventory management, fuel scheduling and reconciliation with network capability. "The cleanest solution is SIRA for leak detection plus a tank gauge for automated inventory data collection where practicable," says Russell Dupuy.

"The best systems meet US EPA standards," says Murray Ekert, General Manager, Metric Australia. "Australia is some 10 to 15 years behind, and regulations will only get tighter not looser. In the United States, all tanks are also fully tested after 10 years. In Australia, BP tests all its tanks every three years, and to a large extent the major oil companies follow the US regulations." John Beard agrees: "Treloar is partly owned by OPW, an American company with many years' experience in compliance with US EPA regulations."

What Does it Cost?
No doubt you are thinking, "What does it cost?" And, that's a fair question. For a basic SIRA system where you do all the work on-site, you will spend a couple of hundred dollars for a site assessment and then around $30 per tank per month. But, don't forget the hidden costs of manually dipping tanks, the associated exposure to hydrocarbons and the presence of moving vehicles. A basic tank gauge will set you back around $5,000 and the Rolls Royce versions carry Rolls Royce prices in the tens of thousands of dollars. This may seem a lot, but is cheap compared to the potential cost of clean-up if your UPSS is leaking.

By the time Balgee Oil discovered the leaks at its Apollo Bay service station in 1999 it was too late. The fuel leaked into the groundwater and the clean-up costs are estimated at $1.5 million. The company was also ordered to pay costs and fines of over $30,000. Penalties are now much higher. "Recent changes to the Act mean the maximum penalty for groundwater contamination is now $240,000 and clean up costs can be considerable depending on the size of the leak," says Doug Ahearne. "It is important to note that taking action under the Guideline does not give immunity from prosecution if there is a breach of the regulations. However, an appropriate leak detection system does decrease the risk and, if there is no system in place and there is serious contamination, look out."

The Apollo Bay incident highlights the importance of establishing whether your site is a "sensitive" site - one that is in close proximity to groundwater and set in permeable ground. All sites must be assessed by February 2005.

"Keep in mind that, even though you have until February 2004 to implement a system, there will be a lot of owners looking for the same service this year," says Reed Leighton.

"I think some retailers are in for a shock, and they are no doubt asking; 'What do I need to do? Who do I ask? How much will it cost?'" says John Beard. "The answer is the Petroleum Industry Contractors Association (PICA). That also means suppliers and contractors will need to be prepared for a barrage of questions."

Start asking now.


Contact details:


WHAT ARE POLLUTION PREVENTION & DETECTION MEASURES?



clearly defines requirements, procedures and responsibilities for management of the UPSS. Should be documented, and a copy kept on-site.


& Double-walled Tank & Piping (also called 'secondary containment') ensures that any potential leak through the inner wall is prevented from immediate release to the environment by the outer wall.

Tank Pit Monitoring Bore may detect petroleum fuel that has leaked or spilled into the tank pit.

Statistical Inventory Reconciliation Analysis (SIRA) is where the inventory, delivery and dispensing data for a UPSS (provided by the operator) is statistically analysed by a SIRA service provider using a sophisticated computer program to determine whether the UPSS is leaking.

& Automatic Tank Gauging plus Line Leak Detection may be used as an alternative to SIRA for leak detection from a UPSS. The tank gauge and line leak detector are permanently installed within the system to monitor the volume of product and indicate whether the UPSS is leaking.

Groundwater Monitoring Bore is installed to monitor the quality of groundwater beneath the site (can detect fuel product floating on top of the groundwater). Groundwater monitoring bores (usually three or more) are required for UPSS located in sensitive environments (for example where a creek runs nearby, or where groundwater is, or may be, used on neighbouring properties).

 

WHAT DO THE GUIDELINES MEAN FOR YOUR UPSS?

If you have an existing UPSS, you need

 UPSS Management System   
  +
or + Leak Detection by February 2004
  +
Groundwater Monitoring Bores at 'Sensitive Sites' by February 2005


If you install a new UPSS after February 2003, you will need

UPSS Management System
  +
Double-Walled Tank
  +
Double-Walled Piping
  +

Tank Pit Observation Bore
  +
or & Leak Detection
  +
Groundwater Monitoring Bores at 'Sensitive Sites'

You need to arrange a review of your UPSS to see whether it is considered to be a 'sensitive site'.
This will help determine whether you need to install groundwater monitoring bores.




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