How to Improve the Quality and

Consistency of Compliance

Inspections

By Brian Wiegert

VP - Inspection/Loss Control/Training Services

Rounds & Associates

515-334-3010

Rounds & Associates

• Nationally recognized as a leader in environmental risk management for petroleum marketing industry.

• Over 100 years combined experience in the petroleum storage tank and risk management industries.

• Services include: Third Party Tank Inspection Services. R&A has conducted over 20,000

petroleum facility inspections throughout the United States for private owners, public companies and regulatory agencies to perform loss control and compliance inspections.

Environmental Claims Management Services. R&A staff have managed over 10,000 environmental claims throughout the United States, providing oversight for private companies, State programs and insurance companies.

Petroleum Storage Tank Training Services. R&A has been recognized nationally as a provider of training programs to the petroleum storage tank industry since 2003; including regulators, inspectors, installers, owners and operators.

R & A has performed inspections for:

• State regulatory agencies as a contracted inspector

representing the state.

• State regulatory agencies as an approved and licensed

independent third party inspector.

• Insurance industry providing loss control services and

regulatory compliance.

• Private companies for loss control, training and regulatory

compliance.

“Why do we do site inspections?”

• Prevent Environmental Impact

(Public Health/Safety)

• Use the findings to train Owner/Operators and Installation/Service Companies to be proactive in prevention.

• Prevent Financial Loss

Field Inspectors

Experienced Properly Trained/Licensed

NOT Part-time Independent third party

Plan your travel

Confirm Client Site Information• Has the Owner/Responsible Party (RP) changed?

• Has the fuel system data changed – removal/addition?

• Will this affect the compliance information that needs

submitted?

Tank floated due to flooding

Has the tank location changed?

“How to improve”

Minimize the confusion to the

owner/ operator

How issues are reported must be consistent from the AHJ

*Avoid hand written reports.

*Keep reports short and concise. (Does your mechanic tell

you everything that’s “not” wrong with your car?)

*Review for inconsistencies between different inspectors.

*Use identical verbiage and code to note what the

violation is.

*Free form text should only be used to identify the issue.

e.g. “meter leaking on NL product on disp #7”

“Keep one eye on the ball

and the other on the issue

at hand”

• “Who” needs to correct it.

• “What” needs to be corrected.

• “When” does it needs to be corrected by.

• “How” do I need to respond.

• Back up your findings with photos that

can be provided to the owner or service

company to avoid additional trip

charges/expense.

We know what causes the release

Hole drilled thru pipe

and tank

Line was passing precision tests with rebar in it.

Concrete rebar “in”

product pipe

Who alters equipment and why?

Is the site operating according to regulatory guidelines

Are the components installed/performing according the

manufacturer guidelines and industry standards such as PEI

recommended practices?

Tank Overfill Device

Fill/Spill

Vent

FIRE!

Is the site operating according to regulatory guidelines

Don’t review “all” paperwork in the “field”

Automate inspection tracking

Inspection Observations of Alternative Fuels

Tank containing Ethanol Tank without Ethanol

Aboveground Biodiesel Facilities

If people know what is expected of them

(most) will respond accordingly

Multi-State Compliance –How do we do it?

Tanks Conference

September 2010

Sunoco’s Business Units

• Petro Chemicals• Coke• Logistics• Refining• Retail Marketing

– 4,700 stations– 870 Owned (AA) or Owned and Operated

(COOP)– Operate in 25 states

• 18 retail / 7 NASCAR only

– License to Operate

Sunoco’s Footprint

State COOP AA Total

PA 140 151 291

NY 73 90 163

NJ 25 76 101

MA 28 47 75

FL 61 0 61

Top 5 States with Highest Ownership Owned Retail Station Footprint

Federal, State and Local Agencies

• US EPA

• State EPA

• Fire Department

• Building Office

• Health Office

• Weights & Measures

How do we track everything?

• Regulatory Updates

• Tank Testing

• Tank Alarms

• Inventory Control Records

• Leak Detection

• Inspections

• Training

Marketing Organization

Marketing

Maintenance RemediationPerformance &

Compliance

4 Area Supervisors With several techs

Retail &Corporate 12 people

12 People:LD, IC & Haz WasteNOV/Test/ LiasonProduct Quality

Supply Chain & Marketing Functions

Portal Examples - Files

Portal Example – Inventory & Inspections

Portal Example – Test Results

Issues

• Local ordinances

• Differences between Federal and State

• Regulations not protective of the environment

• Multi-State Operations

What is...Good Tank Management?

September 22, 2010Scott C. Boorse

22nd National Tanks ConferenceBoston, MA

Agenda

• Disclaimer

• Wawa History & Background

• Establish the Goal?

• What is Good Tank Management?– Understand the requirements– Build it right the first time– Operate & maintain it correctly– Management (understand what it takes to do it right)– Partnerships

• Questions & Answers

Disclaimer

• “This presentation is based on the experiences and observations of one person over the past 20 years, with input from other reputable sources; and the sole opinion and contents are for informational purposes only.”

• “Please do not send any NOV’s if you are not satisfied!”

Our Modern Day BusinessStarted in 1964

• 580 Total Stores– 300 Non-Gasoline

– 280 Gasoline

Store #1, Folsom, Pa

May 1964

Pennsylvania

Virginia

New Jersey

Delaware

Maryland

580+ Stores

4 Decades Later. . .

Company Facts - Annual

• $6.0+ Billion Annual Sales

• 1.5 Billion Gallons of Gasoline sold

• 400M Customer Transactions

• 200M Cups of Coffee

• 56M Sandwiches

• 75M ATM Transactions

What is the Goal?

• Primary Goals of Good Tank Management– Protect the environment! (first & foremost)

• No loss of product

• Minimize any impact

– Protect the consumer• Provide high quality products

• Leads to customer retention

– Make a profit• Must make money to stay in business

• Need funding to operate & maintain sites

What is Good Tank Management?Understand the requirements

• Need to know & understand the requirements– Owner/operators are required to know a LOT!

– Federal, state, & local organizationsEPAStates (i.e. CARB)Local jurisdiction (AHJ’s)Weights & MeasuresTaxation DepartmentsIndemnification FundsPEI & API RP’sManufacture requirements

NFPA/NECOSHAADALabor & IndustryInsurance CompaniesCompany Policies & ProceduresEnvironmental NGO’sGreen Movement/Sustainability

– Information Overload4multi-state operators

What is Good Tank Management?Build it right the first time

“Pay me now or pay me later”

“You get what you pay for”• Materials

– Only use quality materials from reputable sources

– Verify the parts; you only get one chance

• Installation Contractors– Only use licensed, reputable contractors!!

– DO NOT select based solely on low bid

• Keep it Simple: Site design & layout or materials

• Inspect, Detect, & Correct– EPA got it right in 1988

– If your not looking you won’t find it

• Inspect, Detect, & Correct– Be sure system can detect problems

– Once detected they MUST be fixed!

• Inspect, Detect, & Correct– Entire Wawa Gasoline Program based on this

simple principle

What is Good Tank Management?Operate & maintain properly

• Resources– Dedicated O&M and Compliance Dept’s.

– Training & development group

– Outside consultants

• Time– Six full-time associates for 300 stores

– ~40+ hr/store annually

• Cost$ per year– $30K/store & $0.005 per gallon

What is Good Tank Management?Management to do it right

• Partnering for ideas & solutions– No need to recreate the wheel

• Information sharing essential for success– Service vendors & contractors

– Consultants, manufacturers & distributors

– Other end users (owners/operators)

– PEI & API

– Regulatory Community• Ad Hoc groups

What is Good Tank Management?Partnerships

• To summarize...what is good tank mgt?– Understanding the requirements

– Building it right the first time

– Operate & maintain it correctly

– Management (what it takes to do it right)

– Partnerships

What is Good Tank Management?

• Thank you for your time and attentive listening!

• Questions?

What is Good Tank Management?