Wednesday, May 24, 2017  
You are here:  Storage Tank Consulting * Information Exchange   Login

2865 Executive Drive, Suite A, Clearwater Florida 33762  Phone: (727) 571-1444 Marketing Director: Mary McGarvey

     Member Login Member Login


Forgot Password ?

  

First time users please register to join the forums.  Return users please login to participate.

Information Exchange
FDEP Guidance on Breach Testing Double-Wall Steel Tanks
Last Post 06 Sep 2012 04:30 AM by SuperUser Account. 0 Replies.
Printer Friendly
  •  
  •  
  •  
  •  
  •  
Sort:
PrevPrev NextNext
You are not authorized to post a reply.
Author Messages Informative
SuperUser Account
New Member
New Member
Posts:11
Avatar

--
06 Sep 2012 04:30 AM
    This copy of an e-mail thread with Florida DEP and DOH Personnel clarifies the requirements for testing Modern and other double-wall steel tanks. The question was raised when Pinellas County tank inspectors did not accept recently-completed Breach of Integrity (BOI) test results on Modern double-wall tanks because they were not conducted according to Modern's revised test criteria revised on January 4, 2012 (copy attached). Also attached are copies of the DEP equipment approvals for Modern Type I and Glasteel Type II tanks for reference. Also for reference, this link will take you to the recently published DEP BOI-Guidance-Final document: http://dep.state.fl.us/waste/quick_...-Final.pdf

    From: Joseph_Sowers@doh.state.fl.us [mailto:Joseph_Sowers@doh.state.fl.us]
    Sent: Thursday, September 06, 2012 7:57 AM
    To: Steve Miller; Randall_Strauss@doh.state.fl.us
    Cc: Mary McGarvey; Ernest_Roggelin@doh.state.fl.us; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com; bill.burns@dep.state.fl.us; John.Svec@dep.state.fl.us; Kimberley.Curran@dep.state.fl.us
    Subject: RE: [Possible Spam:******* SpamScore] RE: Valley BOI testing

    Good Morning Steve:

    If the tank manufacturer is unknown then I believe the STI R012 would be appropriate with an AP not required. If the tank is a type 1 or jacketed tank then it would be 6” Hg for one hour regardless of depth to water or tank diameter; if I understand the document correctly. If it is a type II then the test parameters would be contingent on tank diameter and calculation of amount of water on the tank. If the tank manufacturer is unknown it is possible that the type is also unknown. If both are unknown we would need to discuss which method would be appropriate but my current inclination would be to use the type II method as “most protective” of the unknown equipment. Hopefully this scenario would be a rare exception.

    For EQ 694 tanks, since the 5.3” Hg is in the EQ we will, and have, accepted 5.3” being held for one hour. Since both test methods are listed in the EQ we will accept either one.

    If you have any other questions or comments please feel free to contact us. Thank you for your patience while we worked through the “question”.
    Joseph Sowers
    Phone: 727-538-7277 xt. 7911
    We value your feedback as a customer. We are committed to continuously assessing and improving the level and quality of services provided to you. To comment on the quality of service you received, simply click on this link to our Customer Survey. Thank you in advance for completing the survey.
    Please consider our environment before printing this e-mail.
    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.
    ________________________________________
    From: Steve Miller [mailto:SteveM@petrolsmart.com]
    Sent: Thursday, September 06, 2012 7:39 AM
    To: Sowers, Joseph; Strauss, Randall
    Cc: Mary McGarvey; Roggelin, Ernest; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com; bill.burns@dep.state.fl.us; John.Svec@dep.state.fl.us; Kimberley.Curran@dep.state.fl.us
    Subject: [Possible Spam:******* SpamScore] RE: Valley BOI testing

    Thanks Joe – I think the Glasteel II EQ is clearer than the Type I EQ.

    For Modern Type I tanks, EQ 694 says on the attached test forms that an initial vacuum of at least 12” of Hg must be applied and if it doesn’t drop more than 5” of Hg in one hour for tanks 10,000 gallons and smaller, or in 2 hours for tanks larger than 10,000 gallons, the tank passes. However, the testing section of the installation instructions, also attached to the EQ, says that according to NFPA 30, if the tank holds 5.3” of Hg for one hour then it passes the test and care must be taken not to damage the tank by applying too much pressure. Which one, or both, is an approved method according to the EQ?

    For Modern Glasteel II tanks, EQ 156 says the initial test pressure must be at least 10” Hg, and if the pressure doesn’t drop more than 5” of Hg in one hour for tanks 10,000 gallons and smaller, or in two hours for tanks larger than 10,000 gallons, the tank passes. That is more straightforward and I have no questions.

    I’m grateful that we don’t have to try to hold test pressures on these tanks for 18-24 hours as proposed. It would have been a nightmare to try to protect the equipment that long if it was unattended and we couldn’t afford the test if it had to be attended for 18-24 hours.

    And finally, if the manufacturer of a steel tank is unknown, then can the testing contractor use the STI R012 procedure without an Alternate Procedure approval?

    Best Regards,
    Steve


    Downstream Data Corporation
    Downstream Inspections, Inc.
    P.O. Box 8595
    Clearwater, FL 33758
    Office: 727-571-1444
    Fax: 727-531-9389
    Cell: 727-421-7423
    E-Mail: Stevem@petrolsmart.com
    Website: downstream-data.com

    From: Joseph_Sowers@doh.state.fl.us [mailto:Joseph_Sowers@doh.state.fl.us]
    Sent: Wednesday, September 05, 2012 4:30 PM
    To: Steve Miller; Randall_Strauss@doh.state.fl.us
    Cc: Mary McGarvey; Ernest_Roggelin@doh.state.fl.us; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com; bill.burns@dep.state.fl.us; John.Svec@dep.state.fl.us; Kimberley.Curran@dep.state.fl.us
    Subject: RE: Valley BOI testing

    Hello Mr. Miller: This office asked FDEP if STI R012 “Recommended Practice for Interstitial Tightness Testing of Existing Underground Double Wall Steel Tanks” was an acceptable method to meet the Department’s Breach of Integrity (BOI) testing requirements.

    To summarize (I have pasted the exact response below.): The decision is if the Equipment Approval (EQ) contains a manufacturer’s test method, then the test method specified in the EQ is the one that must be used. If a test method is not specified in the EQ then either a subsequent manufacturer test method or an industry recognized standard can be used. A review of EQ #’s 156 and 694 indicates those both contain vacuum test methods for testing the tank interstice during installation and therefore would be the methods which are to be used for Modern Welding tanks.

    Also, Mr. Berkle with Valley expressed concern because they were never given field test procedures only installation test procedures. Rule 62-761(3)(a)2. F.A.C. indicates four methods which can be used to meet the requirements of the BOI test. Section 62-761(3)(a)2.c. states “Testing of the interstice for liquid tightness in accordance with manufacturer’s installation instructions” as one of the methods.

    Perhaps an option would be to request an Alternate Procedure to allow for the use of the STI R012 testing procedure as equally protective of the environment as the ones indicated in the EQ’s.

    Please note, no matter what test method is used, all appropriate records must be submitted to document that the test was performed in accordance with the test method.

    Please see the response below from Tallahassee regarding breach of integrity testing.

    From: Burns, Bill
    Sent: Wednesday, September 05, 2012 12:03 PM
    To: Culbreth, Laurel
    Cc: Svec, John; Curran, Kimberley
    Subject: RE: BOI Testing

    Laurel:
    Our suggested approach concerning the topic of selection of breach of integrity testing method:

    1. If specified in the Equipment Approval (EQ); the tank owner/operator must use the manufacturer’s
    specified method at the time of EQ was approved.
    2. If the BOI test method is absent in the EQ Order, either a manufacturer’s or industry recognized (STI, PEI or NFPA)
    test method should be selected by the tank owner/operator.
    The selection of which test method is a business decision for the tank owner/operator.
    Record keeping for the testing should follow the current guidance document.


    Bill




    Joseph Sowers
    Phone: 727-538-7277 xt. 7911
    We value your feedback as a customer. We are committed to continuously assessing and improving the level and quality of services provided to you. To comment on the quality of service you received, simply click on this link to our Customer Survey. Thank you in advance for completing the survey.
    Please consider our environment before printing this e-mail.
    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.
    ________________________________________
    From: Steve Miller [mailto:SteveM@petrolsmart.com]
    Sent: Thursday, August 30, 2012 7:29 AM
    To: Sowers, Joseph; Strauss, Randall
    Cc: Mary McGarvey; Roggelin, Ernest; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com
    Subject: [Possible Spam:****** SpamScore] RE: Valley BOI testing

    It appears to be a completely vetted test method by THE authority on steel tanks. Whether you knew it or not, it is the method used by testers in Florida unless regulators interfere. And it covers all types of tanks produced by Modern. I have had this dialogue with Randy and told him Valley was using the STI RP. Randy was not comfortable with the amount of vacuum Valley was drawing on the tank interstices according to the STI RP and would not accept Valley tests done according to the protocol vacuum limits. There is no point in doing submergence calculations if a regulator is going to insist on pressurizing the tank interstice well beyond the calculated limits of the STI procedure. What you have ended up with in our case is a hybrid test, not vetted by anyone but Randy, that exposes the tank owner to the possibility of a broken tank, and you have increased the probability of having a release and generating false positives. I don’t have to tell you that none of those things is good. Valley would not test at the levels Randy wanted unless I consented and accepted responsibility for the consequences on behalf of the owner. You need to quit monkeying around with this and let testers do their job.

    Downstream Data Corporation
    Downstream Inspections, Inc.
    P.O. Box 8595
    Clearwater, FL 33758
    Office: 727-571-1444
    Fax: 727-531-9389
    Cell: 727-421-7423
    E-Mail: Stevem@petrolsmart.com
    Website: downstream-data.com

    From: Joseph_Sowers@doh.state.fl.us [mailto:Joseph_Sowers@doh.state.fl.us]
    Sent: Wednesday, August 29, 2012 6:51 PM
    To: Steve Miller; Randall_Strauss@doh.state.fl.us
    Cc: Mary McGarvey; Ernest_Roggelin@doh.state.fl.us; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com
    Subject: RE: Valley BOI testing

    Hello Steve: It appears that this RP was written to meet the secondary containment testing requirements for California State Water Resources Control Board. Perhaps to perform tests on tanks where the manufacturer was unknown. I would surmise that someone in the Tanks program office in Tallahassee would need to decide if it can be applied to tanks in Florida.

    I have not had a chance to review in detail but it would seem the amount of vacuum drawn on an interstice is dependent on how far above the bottom of the tank "groundwater" is. I glanced at four interstitial test results and did not see any indication that depth to water was determined or a calculation made to determine if the water was above the bottom of the tank and if so, how far above. I do not know if the sites I looked at have any way of determining DTW. It also appears that if it is a type I tight wrapped then DTW is not a factor. There has not been an assertion in the past that a STI RP was being used. Even if it had been, I do not know if we could have accepted it since it did not come from the manufacturer especially since the manufacturer has provided a testing procedure.

    Joseph Sowers
    PST Compliance & Cleanup Programs / GIS
    Environmental Health and Preparedness Division
    Pinellas County Health Department
    joseph_sowers@doh.state.fl.us
    Phone: 727-538-7277 xt. 7911

    Please consider our environment before printing this e-mail.

    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.

    ________________________________________
    From: Steve Miller [mailto:SteveM@petrolsmart.com]
    Sent: Wed 8/29/2012 5:55 PM
    To: Strauss, Randall
    Cc: Mary McGarvey; Sowers, Joseph; Roggelin, Ernest; Laurel.Culbreth@dep.state.fl.us; Bruce Mitchell (bruce@risseroil.com); gschober@modweldco.com; Brian Berkle (brian@valleytank.com)
    Subject: RE: Valley BOI testing
    Hello Randy – here’s the front page of the document. I cannot send you the standard because it would violate the copyright and as you can see at the bottom of the page, it would lead back to Matthew at Valley. You must be able to access a copy some place in DEP/DOH, right?


    Best Regards,
    Steve

    Downstream Data Corporation
    Downstream Inspections, Inc.
    P.O. Box 8595
    Clearwater, FL 33758
    Office: 727-571-1444
    Fax: 727-531-9389
    Cell: 727-421-7423
    E-Mail: Stevem@petrolsmart.com
    Website: downstream-data.com

    From: Randall_Strauss@doh.state.fl.us [mailto:Randall_Strauss@doh.state.fl.us]
    Sent: Wednesday, August 29, 2012 1:30 PM
    To: Steve Miller
    Cc: Mary McGarvey; Joseph_Sowers@doh.state.fl.us; Ernest_Roggelin@doh.state.fl.us; Laurel.Culbreth@dep.state.fl.us; bruce@risseroil.com; gschober@modweldco.com; brian@valleytank.com
    Subject: RE: Valley BOI testing

    That will be up to them – can you please provide me with a copy of the STI procedure for our files.

    Thanks,


    Randall H Strauss
    Pinellas County Health Dept
    Environmental Health & Preparedness Div
    Mid-County Center
    8751 Ulmerton Rd Suite 2000
    Largo FL 33771
    V 727-538-7277 x7921
    F 727-538-7293
    randall_strauss@doh.state.fl.us

    We value your feedback as a customer. We are committed to continuously assessing and improving the level and quality of services provided to you. To comment on the quality of service you received, simply click on this link to our Customer Survey. Thank you in advance for completing the survey.
    Please consider our environment before printing this e-mail.
    FDOH Mission: Promote, protect and improve the health of all people in Florida.
    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.



    ________________________________________
    From: Steve Miller [mailto:SteveM@petrolsmart.com]
    Sent: Wednesday, August 29, 2012 1:21 PM
    To: Strauss, Randall
    Cc: Mary McGarvey; Sowers, Joseph; Roggelin, Ernest; Laurel.Culbreth@dep.state.fl.us; Bruce Mitchell (bruce@risseroil.com); gschober@modweldco.com; Brian Berkle (brian@valleytank.com)
    Subject: RE: Valley BOI testing

    Randy, can’t Modern simply approve the STI testing method as an approved, 5-year breach test method on their tanks? It seems to me that the costly, time-consuming BOI test method recently published by Modern is a preemptive attempt to move the cost of confirming a failed, STI breach test from the manufacturer (Modern) to the owner. But I’m not sure that was the motivation because the extended test periods in Modern’s recently published BOI test method are sure to result in more failures and false positives than the shorter duration STP test method regardless of whether the interstice is actually tight or not. That would result in more warranty repair claims for Modern AND in increased cost for the owners. I have copied Modern with this chain to invite comments and clarifications since I don’t really understand the motivation for their stringent, costly, time-consuming BOI test method.

    Best Regards,
    Steve

    Downstream Data Corporation
    Downstream Inspections, Inc.
    P.O. Box 8595
    Clearwater, FL 33758
    Office: 727-571-1444
    Fax: 727-531-9389
    Cell: 727-421-7423
    E-Mail: Stevem@petrolsmart.com
    Website: downstream-data.com

    From: Randall_Strauss@doh.state.fl.us [mailto:Randall_Strauss@doh.state.fl.us]
    Sent: Wednesday, August 29, 2012 9:44 AM
    To: Steve Miller
    Cc: Mary McGarvey; Joseph_Sowers@doh.state.fl.us; Ernest_Roggelin@doh.state.fl.us; Laurel.Culbreth@dep.state.fl.us
    Subject: RE: Valley BOI testing

    Steve,

    Here is the excerpt from the Rule, this is 62-761.640(3)(a)2.:

    2. Breach of integrity tests for Category-C systems. A test shall be performed for a breach of integrity of the interstice for double-walled USTs and for double-walled integral piping that is in contact with the soil and that is connected to USTs. Piping sumps and dispenser liners are not required to perform a breach of integrity test. The test shall be performed to determine the integrity of the inner and outer wall, is required only for tanks and integral piping with closed interstices, and does not apply to open-interstice systems with liners. The test shall be performed at the time of installation, and every five years from the date of installation, unless the test is a continuous test. If a UST is totally submerged in groundwater, monthly monitoring of the interstice for the presence of water shall be conducted. The breach of integrity test may be performed by using at least one of the following methods:
    a. A continuous hydrostatic system approved by the Department in accordance with subsection 62-761.850(2), F.A.C.;
    b. A continuous vacuum system, pursuant to paragraph 62-761.640(3)(a), F.A.C., that is approved by the Department in accordance with subsection 62-761.850(2), F.A.C.;
    c. Testing of the interstice for liquid tightness in accordance with manufacturer’s installation instructions; or
    d. Another method in accordance with subsection 62-761.850(2), F.A.C.

    The d. reference is to another method listed specifically in the equipment approval, for example Tank Tech’s lining approval has specification for the testing listed in the approval with the parameters and the 2-year requirement instead of 5-year

    And I have attached the DEP guidance that is posted on the Regulation page web site, with added emphasis on this requirement on page 2

    Randall H Strauss
    Pinellas County Health Dept
    Environmental Health & Preparedness Div
    Mid-County Center
    8751 Ulmerton Rd Suite 2000
    Largo FL 33771
    V 727-538-7277 x7921
    F 727-538-7293
    randall_strauss@doh.state.fl.us

    We value your feedback as a customer. We are committed to continuously assessing and improving the level and quality of services provided to you. To comment on the quality of service you received, simply click on this link to our Customer Survey. Thank you in advance for completing the survey.
    Please consider our environment before printing this e-mail.
    FDOH Mission: Promote, protect and improve the health of all people in Florida.
    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.



    ________________________________________
    From: Steve Miller [mailto:SteveM@petrolsmart.com]
    Sent: Wednesday, August 29, 2012 9:04 AM
    To: Strauss, Randall
    Cc: Mary McGarvey; Sowers, Joseph; Roggelin, Ernest
    Subject: Re: Valley BOI testing

    Hello Randy - I think they are using STI protocol. Where is it written that the manufacturer's protocol has to be used to the exclusion of all other test protocols?

    Best Regards,
    Steve
    Sent from my Verizon Wireless BlackBerry
    ________________________________________
    From: "Randall_Strauss@doh.state.fl.us" <Randall_Strauss@doh.state.fl.us>
    Date: Tue, 28 Aug 2012 16:05:21 -0400
    To: Mary McGarvey<MaryM@petrolsmart.com>; Steve Miller<SteveM@petrolsmart.com>
    Cc: Joseph_Sowers@doh.state.fl.us<Joseph_Sowers@doh.state.fl.us>
    Subject: Valley BOI testing

    Mary and Steve,

    Just to give you guys a heads up on another issue – I think you will recall Steve we discussed this at some length when you first told me about retaining Valley to do all your testing in July. I have just begun doing all the file reviews for the inspections Tom and I did last week; however, the first BOI test done by Valley that I reviewed was not done in accordance with mfgr specs, so it will be cited as still needing to be done (this was at Rally 137). I suspect that there could be more, if not all, that this will apply to, as Valley has not generally been in agreement to follow the mfgr specs, as we discussed.

    Just FYI Steve, I did receive all of your e-mails with the testing but I had not had a chance yet to go through it all, which is why a citation wasn’t corrected yet that I think spawned the e-mails between you and Joe, as he was not aware all that was still pending my review.

    Randall H Strauss
    Pinellas County Health Dept
    Environmental Health & Preparedness Div
    Mid-County Center
    8751 Ulmerton Rd Suite 2000
    Largo FL 33771
    V 727-538-7277 x7921
    F 727-538-7293
    randall_strauss@doh.state.fl.us

    We value your feedback as a customer. We are committed to continuously assessing and improving the level and quality of services provided to you. To comment on the quality of service you received, simply click on this link to our Customer Survey. Thank you in advance for completing the survey.
    Please consider our environment before printing this e-mail.
    FDOH Mission: Promote, protect and improve the health of all people in Florida.
    Please note: Florida has a very broad public records law. Most written communications to or from state officials regarding state business are public records available to the public and media upon request. This e-mail communication may therefore be subject to public disclosure.




    Orlando-Interstitial_Subsidiary_Copy_Test_Times_1-
    EQ-156.pdf
    EQ-694.pdf

    You are not authorized to post a reply.


    Active Forums 4.3
      
    Home  |  Contacts  |  Storage Tank Consulting  |  Cloud Application Development  |  Industry Links
    Copyright 2005 Downsteam Data Corporation   |  Privacy Statement  |  Terms Of Use