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Stage I Vapor Recovery TestingResults of Testing for NESHAP Regulations 40CFR63 Part CCCCCC

ASTSWMO Conference March 2, 2011

Brad Hoffman

Outline

•

Overview of NESHAP Regulation and Equipment Requirements

•

Stage I Vapor Recovery Testing Requirements•

Static Pressure (Pressure Decay) Test•

Pressure Vacuum Vent Valve (PV Vent Cap) Test

•

Results of Tanknology Testing Program in 2010

Overview of Regulation

•

National Air Toxic Standards for Gasoline Dispensing Facilities

40CFR63 Subpart CCCCCC

•

This is part of NESHAP –

National Emission Standards for Hazardous Air Pollutants

•

This presentation covers basic equipment and testing requirements. •

For complete text of regulation including detailed requirements,

definitions, and notification and recordkeeping requirements and deadlines see:•

http://www.epa.gov/ttn/atw/area/arearules.html

•

http://www.epa.gov/ttn/oarpg/ramain.html•

http://ecfr.gpoaccess.gov

Basic Equipment Requirements

•

GDF’s with < 10,000 gallons throughput/month•

Tight fill (Gasketed

seal on fill pipe)

•

GDF’s with ≥≥

10,000 gallons throughput/month•

Tight fill with submerged drop tube•

No more than 12” from bottom if installed before 11/09/2006

•

No more than 6” from bottom if installed after 11/09/2006

Some tank owners may choose straight cut for safety reasons.

Diagram from CARB

https://www.opw-fc.com/product_detail.aspx?pid=59

Requirements for GDF’s with ≥≥100K thruput

•

Either comply with “Table 1”, or•

Have an existing vapor balance system prior to 1/10/2008 that’s in compliance with an enforceable rule that requires 90% emissions reduction.

Requirements for

GDF’s

with ≥≥100K

thruput

•

GDF’s with ≥≥

100,000 gallons throughput/month•

All of above, and operate a vapor balance (Stage I) system•

Vapor connections seal upon disconnect (dry-break)•

Vapor line from tank to tanker truck must be vapor-tight•

Vapor recovery and product adaptors must prevent over-

tightening or loosening

during deliveries (swivel adaptors or locking collars/clamps?)

•

Vapor balance system designed to not exceed 18” w.c. pressure or 5.9” w.c. vacuum in tank truck during delivery

•

Any separate gauge port must have drop tube as above•

Must have Dual Point system if installed after 11/09/2006

OPW 633LC

OPW 61SAOPW 61VSA

Requirements from “Table 1”

Swivel Fill and Vapor

Adaptors



Testing Requirements

Revision in January 2011 may allow alternate test ST-30. Currently under review by EPA.

Applies to sites with ≥≥100K

gal/monththroughput

Pressure Decay Test

P/V Vent Valve Test

Overview of Testing Requirements

•

For GDF’s

with throughput of 100,000 gallons or more per month•

Pressure Decay Test (Static Pressure Test)•

Initially and every 3 years

•

Per CARB TP-201.3 Determination of 2-Inch W.C. Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities amended March 17, 1999

•

Pressure/Vacuum (P/V) Vent Valve Test•

Initially and every 3 years

•

Per CARB TP-201.1E Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, adopted October 8, 2003

Deadline for Testing

Test by July 10, 2011 for systems installed before 12/15/2009.

Test upon installation for new systems.

Pressure Decay Test -

Overview

•

Prior to 1998 most tanks had an annual tightness test that included the ullage space. But now most tanks have ATG or SIR and never have the ullage space checked for leaks, which allows the potential releases of fuel and vapors into the environment.

•

The Pressure Decay Test verifies the tightness of the entire vapor recovery system, including tank top fittings, vent and vapor piping, and tank ullage space.

Pressure Decay Test Procedure

1.

Nitrogen is introduced to the system at a rate between 1 & 5 CFM.

2.

Stabilize pressure at 2.0” w.c.

3.

The Vapor Manifold Test is conducted by verifying pressure on the PV vent cap, dry breaks or other fittings on the UST.

4.

The Pressure Decay test is a 5 minute test with readings taken every minute.

Pressure Decay Test Requirements

•

No fuel delivery within 3 hours before starting a test.

•

The minimum ullage for each individual tank shall be 1000 gallons or 25% of the tanks capacity.

•

The maximum total ullage for all manifolded tanks shall not exceed 25,000 gallons.

•

No dispensing is allowed within 30 minutes of the the test.

•

There should be no A/L testing within 24 hours of the test.

•

Caps must be removed from fill and vapor adaptors.

Referenced alternate ST-30 (1994) test procedure allows for testing with fill caps on. The current version (2002) requires testing with

caps off. Currently under review by EPA Air Toxics Group.

Pressure Decay Test Equipment

•

A Vapor Coupler Test Assembly (poppet adaptor) can be used to hook the hose to the UST.

•

There is a bolt on the inside of the adaptor that depresses the check valve in the dry break to allow nitrogen into the system. 1 PSI Relief Valve1 PSI Relief Valve

Pressure Decay Test –

Pass/Fail Criteria

•

Measure product level in USTs

to calculate the amount of “allowable decay” for the test.

•

The allowable decay rate is calculated by the total amount of ullage space in the combined USTs and quantity of nozzles on site (for Stage II systems).

•

Example: Use the tank charts or ATG system for this calculation.3 tanks all are 10,369 gallons with 20 balance nozzles.Regular tank has 9125 Gallons; Midgrade has 8085; Premium has 9599.

•

The ullage space is calculated by subtracting the amount of product in the tank from its total capacity.

10369-9125 = 1244; 10369-8085 = 2284; 10369-9599 = 770Total Ullage space = 4298 (1244+2284+770)

•

Look up on the chart for balance

systems the allowable decay for 4298 gallons of ullage with 20 nozzles.

This criteria applies to systems with Stage II Vapor Recovery.For GDF’s with only Stage I use the chart for (1-6) Assist Nozzles.


“Balance” Criteria

•

This chart is from the TP 201.3 Test Procedure for Balance Systems.

•

When the ullage space does not match exactly round up to the closest value on the chart.

•

The chart gives the allowable decay for the example from the prior page. In this case the pressure can fall from 2”w.c. to 1.65”w.c.

•

For sites without Stage II use the chart for Assist Systems With 1-6 Nozzles on the next page.


“Assist” Criteria

•

This chart is from the TP 201.3 Test Procedure for Assist Systems.

•

For Stage I sites without Stage II use the chart for Assist Systems With 1-6 Nozzles.

•

When the ullage space does not match exactly round up to the closest value on the chart.

•

For a Stage I system with 4500 gallons of ullage, the pressure may drop from 2.0”w.c. to 1.79”w.c.


Troubleshooting

•

Troubleshooting is the key to the test.

•

It is always good to have a vapor detector to detect vapors.

Step 1 in troubleshooting is to use the vapor detector and or soapy water to begin searching for a leak.The soap and water when sprayed on a leak will bubble and allow you to visibly see where the leak is located.It is important to double check each fitting since the air movement may effect the leaking vapor.


Troubleshooting

Spill ContainersDrain valves and cracks

PV Vent Caps & connectionsFill Adaptors (gaskets)Dry Break Adaptor for Stage I

Gasket and Poppet ValveDrop Tube Leaks and o-ringsRemote FillsSTP Packer Manifold O-ringATG Caps and Cord GripsFill/Vapor Caps Vent stack jointsVent and Vapor Recovery PipingTank Manway gasketsTank Tops (bungs, fittings, risers)Dispensers

Nozzle (Internal Check Valve)HoseBreakawayWhip HoseDispenser piping Vacuum Pumps

Pressure Decay Testing Results

•

Results for Tanknology’s

2010 Testing Program•

*Many tests require troubleshooting to locate and repair leaks.•

72% of sites were able to pass during the first visit after troubleshooting and minor repairs were completed.

•

28% of sites failed and required additional repairs, even after troubleshooting and minor repairs.

•

Includes “manifolded” and “individual” tests.

Number of Tests 3412Number that Passed*

(* includes minor repairs) 2465Percent that Passed*

(* includes minor repairs) 72%Number with Failures 947Percent with Failures 28%

Pressure Decay Failures –

STP Sump

•

Possible leaks in STP Sump

Manway

Vent Piping

Extractor Fitting

LD Vent Tube

STP O-Ring

Pressure Decay Failures -

Tank

•

Crack in fiberglass tank –

view from inside


Tank

•

Leaking tank manway gasket


Riser

•

Severely Corroded Riser Pipe


Riser

•

Severely Corroded ATG Riser and Bad Cap


Riser

•

Severely Corroded Vapor Recovery Riser


LD Vent Tube

•

Leak Detector Vent Tube on STP


LD Vent Tubes

•

Leaking Vent Tubes from Leak Detectors


Vent Piping

•

Cracked Vent Line. Had been damaged by installation of anode for C.P. system.

Anode


Vent Piping

•

Leaking Vent Pipe –

Flex Connector inside boot


St. II Piping

•

Stage II Vapor Recovery Piping


Vent Piping

•

Vent Pipes cut by concrete saw

Pressure Decay Failures

•

Vent Pipe cut by concrete saw


•

Vent Pipes cut by concrete saw during upgrade. Shown during repair.


•

Vent Pipe cut by concrete saw. Patched with tape???


•

Vent Pipe –

with slot cut by concrete saw during upgrades. Patched with tape and buried.


Vent Risers

•

Holes in vent pipe during installation of cover sleeve


Dry Break

•

Dry Break Poppet Valve –

Stage I V.R. Adapter


ATG Cap

•

Corroded ATG Riser and Cap


ATG Cap

•

Leaking ATG Cap –

Compression Fitting


ATG Cap

•

ATG Cap –

Broken Cord Grip


Spill Container

•

Leaking drain valve in spill container (soap test)


Spill Container

•

Spill Container –

cracked at riser threads


Spill Container

•

Cracked Spill Container

Note the crack at the spill bucket drain blank location. Seems as though the bucket is thinner where the drain bore is, and if someone

overtightens

a 4 inch nipple, then a crack appears.


Spill Container

•

Cracked Spill Container


Drop Tube

•

Drop Tube “mangled”


Drop Tube

•

Coaxial Poppeted

Drop Tube –

Spring Broken


Drop Tube

•

Drop Tube “flange” is broken off


Drop Tube

•

Drop Tube –

incorrectly installed


Drop Tube

•

“Extra” holes drilled in drop tube

When tubes were assembled in field, the installer

drilled 3 separate holes in top of tube and collar instead of using factory supplied holes. As a result, all four factory holes leaked in all six tubes. I did as customer

asked, and filled holes with epoxy and retested. All repaired tubes passed.


Drop Tube

•

Field Fabricated Drop Tube (for E-85) Leaking


Drop Tube

•

Drop Tube Weep Holes –

“Repaired” with Seal-Fast?

Pressure Decay Tests –

Minor* Repairs

•

Many minor repairs are performed during testing•

Replace Parts•

Gaskets on fill/vapor adaptors•

Caps on fill/vapor adaptors•

Gaskets in caps on fill/vapor adaptors•

Drain valves in Spill Container•

PV Vent Caps•

Caps on ATG riser •

Cord grips on ATG cap•

O-rings on STP•

O-rings in Drop Tubes•

Vent tubes on Leak Detectors•

Drop Tubes•

Repair weep holes in Drop Tubes with epoxy•

Hoses/Nozzles/Breakaways for Stage II Locations•

*Minor Repairs may add up to significant cost


Major Repairs

•

Vent Piping•

Risers (Fill Pipe, ATG Pipe, Vapor Recovery)

•

Tank Top Fittings•

Tank Manway Gaskets

•

Tank Leaks•

Remote Fill Piping and Drop Tubes

•

Vapor Recovery Piping (for St. II areas)•

Dispenser Vapor Piping (for St. II areas)

•

These “major” repairs usually require the services of a pump and tank contractor and may require excavation

“Unusual” Vapor Recovery System

•

Vapor Balance System? Dual Point System? •

Dry Break is in the STP sump under a 36” manhole cover.

•

How would this ever be utilized?

“Unusual” Vapor Recovery System

•

Dry Break frozen under ice.•

Dual Point system?

•

Has this been maintained? •

How would this be utilized?

PV Vent Valve Testing -

Overview

•

Pressure/Vacuum (PV) Vent Valves are installed at the top of the vent pipe for a gasoline storage tank. They are also called PV Vent Caps.

•

The PV Vent Caps are designed to hold a slight pressure to prevent gasoline vapors from escaping and a slight vacuum to prevent excess outside air from entering the tank.

•

For safety reasons, the PV vent caps have valves that open at predetermined settings if excessive pressure or vacuum builds up in a tank.

•

Some tanks have an independent PV vent caps and sometimes the vent pipes are manifolded together (either above or below grade) and there’s only one vent cap installed.

PV Vent Valves -

Specifications

•

Table 1 to Subpart CCCCCC of Part 63—Applicability Criteria and Management Practices for Gasoline Dispensing Facilities With Monthly Throughput of 100,000 Gallons of Gasoline or More

•

(g) Pressure/vacuum (PV) vent valves shall be installed on the storage tank vent pipes.

•

The pressure specifications for PV vent valves shall be: •

a positive pressure setting of 2.5 to 6.0 inches of water and •

a negative pressure setting of 6.0 to 10.0 inches of water. •

The total leak rate of all PV vent valves at an affected facility, including connections, shall not exceed •

0.17 cubic foot per hour at a pressure of 2.0 inches of water and •

0.63 cubic foot per hour at a vacuum of 4 inches of water.

Models of PV Vent Caps

•

Only “precision” PV Vent Caps will be able to meet these requirements.

•

“Rain Caps” that are open to atmosphere won’t hold any pressure or vacuum.

•

Some PV Vent Caps have the wrong pressure and vacuum settings.

•

Some PV Vent Caps have been certified by CARB but certification isn’t required in most other states.

•

The following pages show some of the available models of PV Vent Caps with ratings that may meet the requirements.

PV Vent Caps (EBW &

Emco)

Emco Wheaton A0084

New samples tested tight but older models didn’t pass.

New Part No. 567673.A0084-038 – 2” Screw-onA0084-103 –

2” Clamp-on

EBW 802-308-01

Should be available with proper pressure and vacuum settings.

PV Vent Caps (OPW)

OPW 623V (old)OPW 523V

523V-2203 2" Size Thread-on. 3" wc pres., 8" wc vac.

523V-2253 2" Size Slip-on. 3" wc pres., 8" wc vac.

623V-2203 2" Thread-on

623V-3203 3" Thread-on

Some existing caps might be able to pass tests. Not recommended as

replacements.623V was been de-certified by CARB for EVR but should be o.k. in most

other states.

Some older versions of these caps may have cracking pressures from 2.5” –

3.5” w.c. but current OPW specs are 2.5” –

6.0”w.c.

OPW 623V (new)

PV Vent Caps (Husky and Morrison)

Morrison Bros.749-CRB

Husky 4885 or 5885

4885 may be used anywhere except in CA.

5885 is certified by CARB.

Should be available with proper pressure and vacuum settings.

Four tests required for each PV Vent Cap

1. Positive Leak Rate Test at 2.0” w.c.Measures how much air (vapor) can leak past the valve before it “cracks”

open.

2. Positive Cracking Pressure at 120 ml/minMeasures the amount of pressure it takes to cause the valve to “open”

up. After the valve “cracks”

it won’t hold quite as much pressure.

3. Negative Leak Rate Test at – 4.0” w.c.Measures how much air can leak past the valve before it “cracks”

open.

4. Negative Cracking Pressure at 200 ml/minMeasures the amount of vacuum it takes to cause the valve to “open”

up when vacuum is building up. After the valve “cracks”

it won’t hold quite as much vacuum.

Thresholds for “Individual” Tests

1. Positive Leak Rate Test at 2.0” w.c. Must be ≤

23.6 ml/min (0.05CFH)

2. Positive Cracking Pressure at 120 ml/minMust be between 2.5” – 6.0” w.c.

3. Negative Leak Rate Test at –4.0” w.c. Must be ≤

99.1 ml/min (0.21 CFH)

4. Negative Cracking Pressure at 200 ml/min Must be between 6.0” and 10.0” w.c.

These thresholds are based on Federal EPA rules for tests required every 3

years. Other standards may apply for other tests done per local Stage II Vapor

Recovery regulations.

(unless other manufacturer specifications apply)

Caps must meet total leak rate requirements for the entire site as

well. See next page for details.

Threshold for “All Valves” at one site

In addition to passing the individual tests, the leak rates for all valves at each site must be added together. The total leak rate of all valves must meet following:

1. Positive Leak Rate Test at 2.0” w.c. Must be ≤

80.2 ml/min (0.17 CFH)

3. Negative Leak Rate Test at –4.0” w.c. Must be ≤

297.3 ml/min (0.63 CFH)

Conversion Factors:

1 CFH = 471.95 ml/min

1 ml/min = 0.00212 CFH

Caps must meet individual specifications as well. See

prior page for details.

PV Vent Cap Tester –

Front View

0 – 200ml/min

Flow Meter for Vacuum

Tests

Digital Manometer0 – 20” w.c. range with at least 0.5% accuracy.

0 – 200 ml/min

Flow Meter for Pressure

Tests

Directional Valve

A. Positive Leak Rate Test

1.

Open valve on pressure flow meter slowly until pressure stabilizes at 2” w.c. on digital manometer.

2.

Stabilize for 10 seconds (+/-

0.05” w.c.)

3.

Record flow rate

in ml/min

from flow meter.

4.

Multiply by 0.00212

to get flow rate in

CFH.

Must be ≤

23.6 ml/min or 0.05 CFH to pass(unless other manufacturer requirements apply)

AND total of all caps must be ≤

80.2 ml/min (0.17 CFH)

Record flow inml/min

Example:

13 ml/min

x 0.00212 = 0.027 CFH PASS

Stabilize pressure at 2” w.c.

INWC

2.00

B. Positive Cracking Pressure

1.

Open the by-pass valve.2.

Open valve on pressure flow meter until flow stabilizes at 120 ml/min.

3.

Close by-pass valve.4.

Observe manometer.

5.

Record highest pressure achieved (cracking pressure) before

pressure drops.

(unless more stringent manufacturer requirements listed on cap)

Set flow to 120 ml/min

Must measure between 2.5” – 6.0” w.c. to pass

Thenrecord

cracking pressure

INWC

3.20

C. Negative Leak Rate

1.

Connect nitrogen hose to venturi vacuum generator.

2.

Open vacuum flow valve slowly until manometer stabilizes at -4”w.c.

3.

Stabilize vacuum for 10 seconds (+/-

0.05”w.c.)4.

Record flow rate

in ml/min

from flow meter.

5.

Multiply by 0.00212

to get

flow rate in

CFH

Stabilize vacuum at

-4”w.c.

Record flow inml/min

Must be ≤

99.1 ml/min or 0.21 CFH to pass(unless other manufacturer requirements apply)

AND total of all caps must be ≤

297.3 ml/min (0.63 CFH)

Example:

27 ml/min

x 0.00212 = 0.057 CFH PASS

INWC

-4.00

D. Negative Cracking Pressure

1.

Open the by-pass valve.2.

Open valve on vacuum flow meter until flow stabilizes at 200 ml/min.

3.

Close by-pass valve.4.

Observe manometer.

5.

Record highest pressure achieved (cracking pressure) before

pressure drops.

“Negative pressure” is the same as “Vacuum”

(unless more stringent manufacturer requirements listed on cap)

Must be between -6.0” and -10.0” w.c. to pass

Then record

cracking “pressure”

Set flow to200 ml/min

INWC

-7.74

Field Data Sheet

•Record the Manufacturer’s specified leak rates on the form. •Record readings in ml/min and then calculate CFH.•Each valve must pass all 4 tests in order to pass, AND•The total leak rate for the site must be under the limits (0.17cfh and 0.63cfh)

PV Vent Valve Tests –

Findings

•

Most old “Non-EVR” caps won’t be able to pass test.•

New “EVR-type” caps should be able to pass test.

•

Sites with 4 or more vents may have trouble passing for total leak rate. These sites may need to have vents manifolded in order to pass, or else have vent valves with very low leak rates.

?

PV Vent Valve Testing -

Findings

•

Vent pipes must be threaded to accept “EVR” type PV Vent Valves. Slip-on adapters may be acceptable in some areas, but not in CA.

•

Vent Valves may need to be cleaned prior to testing in order to pass (with soapy water –

no oils or lubricants).

•

PV Vent Valves are “precision” devices and may need annual maintenance to remain functional. Follow manufacturer’s recommendations.

OPW 523V-1150 or 523V-3100

PV Vent Cap Testing Results -

Overall

•

Overall Results for Tanknology’s 2010 Stage I Testing Program•

39% of vents had caps that passed the test, including some that were installed by tank owner in preparation for test.

•

61% of vents had caps that failed the test. •

The number of “Failed” tests includes vents with rain caps and other “non-EVR” type caps that weren’t rated for 3”w.c. pressure and 8”w.c. vacuum.

TOTAL NUMBER OF EXISTING VENT CAPS 9552Number Passed 3755Percent Passed 39%Number Failed 5797Percent Failed 61%

PV Vent Cap Testing Results by Make/Model

•

Test results for the most commonly found “newer-style” PV Vent Caps •

Doesn’t include “rain caps” or “wrong-model” type caps•

Doesn’t include results of new replacement caps•

Some vent caps had been installed prior to the testing program, while other caps may have been installed for many years.

•

Some caps may have been cleaned prior to testing as allowed by the inspector or regulatory agency.

Make of Cap Husky Husky Morrison OPW OPWModel of Cap 4885 5885 749CRB 523V Series 623V SeriesTotal Existing Caps 437 237 60 1324 2543Number Passed 373 223 47 679 2414Percent Passed 85% 94% 78% 51% 95%Number Failed 64 14 13 645 129Percent Failed 15% 6% 22% 49% 5%

PV Vent Cap Testing -

Failures

•

Rain Caps •

Don’t have Pressure or Vacuum Poppet Valves

•

No Caps Present•

Not able to be tested

•

Very common at GDF’s that have never been

tested.•

Must install and test new caps


Failures

•

Wrong Model or Older Version PV Caps •

“Wrong” pressure and vacuum settings.

•

Usually won’t hold proper amount of pressure or vacuum.

•

Usually “leak” more than allowable leak rate.

•

Sometimes have red or blue or gray decal instead of yellow.

•

Older Caps•

Gaskets hardened•

Springs rusted or broken•

Filled with dust/debris

Model Number Pressure/Vacuum Settings Label

523V-1100 8 oz pres., 1/2 oz. Vac. Red

523V-2300 12 oz pres., 1/2 oz. Vac. Blue

523V-2200 1 oz pres., 1/2 oz. Vac. Silver

Examples of some older OPW vent caps.


Failures

•

Multiple Vents•

Will probably exceed the total allowable leak rate for site

•

Especially for existing older style caps

•

Will need to have vent pipes manifolded together

PV Vent Cap Failures

•

Found “empty” shell with internal valves missing. How? Why?

PV Vent Cap Failures

•

Vent Cap contains “sawdust” of some type???

Overall Results of Testing Program

•

Stage I Vapor Recovery System that won’t release vapors into the atmosphere.

•

Tight tank-tops and vapor piping to prevent leaks into the tank backfill

•

Cleaner environment for everyone.

Final Points & Questions

•

If Stage II systems are abandoned due to “widespread-use” then GDF’s

will need to

comply with Stage I regulations.•

Which agencies will enforce and interpret regulations (Region EPA Air Offices or State Agencies)?

•

Will the alternate ST-30 Test Procedure be allowed?

•

Deadline for testing has been extended to July 10, 2011.

For Further Information

Brad HoffmanVP Engineering and R&D

Tanknology11000 N. Mopac Expressway Suite 500

Austin, TX 78759(800) 800-4633(512) 380-7154

www.tanknology.combhoffman “at” tanknology “dot” com

http://www.epa.gov/ttn/atw/area/arearules.html

http://www.arb.ca.gov/vapor/vapor.htm

Credits have been given whenever possible for references to other companies or photos from outside sources. Please contact me with any concerns.

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