Florida Cause of Leak Study

Background Info – Florida’s Tanks Program

2005 Single-wall USTs 60%

ASTs with Secondary Containment 80%

18,040

16,286

ASTs

USTs

3,954

11,937 Source - STCM, Feb 05

Double-wall USTs - 40%

Single-wall ASTs - 20%

Total Facility Inspections Performed in Florida

Source: STCM, Feb 05

35000 30000 25000 20000 Inspections 15000 10000 5000 0 '84

'86

'88

'90

'92

'94

'96

'98

'00

'02

'04

436,121 Total Inspections Performed

Petroleum Discharge Report Forms Received Discharges

Source: STCM, Feb 05

7000 6303

6000 5000 4000 3467 3385

3000 2341

2330

2000

1834 1775 1374

1000 0

1010 326 141 4 18 19 53

1298 1206 1271 987 881 597504537615564

'80 '82 '84 '86 '88 '90 '92 '94 '96 '98 '00 '02 '04

32,769 Total Discharge Report Forms Received

23

Post-1998 Petroleum Discharge Report Forms Received Source: STCM, Feb 05

Discharges 1400

1271

1200 1000

881

800

597

600

504

537

615

564

400 200

23

0 '98

'99

'00

'01

'02

'03

'04

4992 Post-1998 Discharge Report Forms Received

'05

Summary - Florida Cause of Leak Study

¾ ¾ ¾ ¾ ¾

Florida Identified Reported Releases (1995-2002) Florida Contracted with County Inspectors to Review Release Sites and Document Information Completed Forms Sent to EPA for Data Entry & Analysis Various Quality Control Steps Current Status - EPA Report is ready for Peer Review

Methodology

Invalid Files Include: •Releases from Bare Steel UST Systems •Release From Non-Compliant Component •Release of Old UST/AST Found at Closure •Unknown Sources

Size of Study ƒ 2280 Release Files Reviewed ƒ 642 Valid Release Files ƒ 512 UST Releases ƒ 130 AST Releases

AST Results

Sources of Releases Other 16%

Dispenser 12%

Tank 5%

Delivery 32%

Piping 35%

Other Sources Include: Fuel Filters, Outlet Valve, and Human Spilling

Causes of Releases Other 16%

Phys/Mech Damage 19%

Loose Unknown Component 8% 12% Corrosion 9% Spill/Overfill 36%

Other Causes Include: Vandalism, Valve Failure, Contractor Accident, Other Human Error

Causes of Piping Release Phys/Mech Damage 29%

Corrosion 26%

Puncture 2% Other 9% Unknown 13%

Loose Component 21%

Method of Detection Closure/ Removal 8%

Other 2%

Leak Detection 22%

Visual/ Olfactory 68%

Success of Leak Detection LD Detected 22%

LD Failed 8% LD Unable, or Unknow n 70%

LD Unable, or Unknown: Either the release came from a part of the system that a LD system was not designed to detect, or the inspector could not determine whether LD failed to detect.

Overfills and Piping

UST Results

Sources of Releases - USTs Turbine P ump 10% Other 11%

Dispenser 25%

Tank 12% Spill/Overfill in Fill A rea 19%

P iping 23%

- Tank Usage Versus Releases 70% 60% 50% 40% 30% 20% 10% 0%

% releases

er th O

lad C

as rg l

Fi be

St

ee

s

l

% usage

Clad Tanks Had Relatively Fewer Releases

- Causes of Tank Releases Other 13% Unknown 14% Phys/Mech Damage 22%

Loose Component 8%Corrosion 16% Puncture 27%

Primary Cause of Steel Tank Release – Corrosion Primary Cause of Fiberglass Tank Release - Puncture

- Piping Usage Versus Releases 80 60 % release

40

%usage

20 0 Steel

Fiberglass

Flexible Plastic

Further Analysis Required to Determine Statistical Significance

- Causes of Piping Releases Corrosion Puncture 7% 15% Other 16% Unknown 20%

Phys/Mech Damage 22%

Loose Component 20%

•Primary Cause of Steel Piping Release – Corrosion •Primary Cause of Fiberglass Piping Release – Loose Component

•Primary Cause of Flexible Plastic Piping – Phys/Mech Damage

Summary of Causes - USTs Other 16% Unknown 17% Phys/Mech Damage 13%

Overfill 12%

Loose Component 18% Corrosion 4% Puncture 8% Spill 12%

Other Releases Include: Delivery to Monitoring Well, Vehicle Accident, Improper Installation, Vandalism

- Success of Leak Detection LD Detected 25% LD Unable, or Unknown 50% LD Failed 25% LD Unable, or Unknown: Either the release came from a part of the system that a LD system was not designed to detect, or the inspector could not determine whether LD failed to detect.

- Method of Detection % of Detections 40 30 20 10

Visual/ Olfactory Leak Detection

Closure/ Removal

Compliance Inspector

Other

0 Other Methods Include: Unscheduled TTT/LTT, Dispenser Upgrades, Maintenance Inspections, Water in Tank

Piping, Dispensers & Spill Buckets

Florida Leak Autopsy Study •Field-verified, Quality assurance •County Tanks Inspectors Complete Forms •Continuation of Florida Cause of Leak Study •Data compared to Forms submitted by tank owners

Material

Other Attributes

Ancillary Equipment

Galvanized Steel

Sacrificial Anodes



Spill Containment Bucket

Fiberglass

Impressed Current System



No Spill Containment

Composite

Internal Lining



Overfill Protection

Unprotected Steel

Single Wall



Ball Check Valve

Other Approved

Double Wall (same material)



Flow Shut-Off

Concrete

Double Wall (different material)



Tight Fill

Polyethylene

Secondary Containment with a liner



Alarm System

Unknown

Other Approved (Tank Bladders, etc.)

Remote Fill

Other (Specify)

Compartmented



No Overfill Protection



External Liner



Other (Specify)

Florida Leak Autopsy Study Four Page Form

Florida Leak Autopsy Forms 1 Jan 03 – 1 Mar 05 Valid AST Discharges 30%

Invalid AST Forms 2%

•859 Forms Forms under investigation 1%

Valid UST Discharges 34%

Invalid UST Forms 33%

UST Sources Dispenser & Piping Sumps 1%

Dispensers 16%

Line Leak Detectors 2% Overfills Submersible Turbine 5% Pumps 4%

Piping 18%

Spill Buckets 31%

305 Valid Forms Fill Pipes 3%

Tanks 10%

Flex connectors & Swing joints 4%

Vehicles, Vapor recovery, vent lines, vandalism and shear valves 6%

Tanks – 10% Double-wall tanks – 2% Single-Wall Fiberglass Tanks

14

2

Single-Wall Internally Lined Tanks

5 1

Single-Wall Composite Tanks

5

1

2 Unknown

Double-Wall Fiberglass Tanks Double-Wall Composite Tanks

Single-Wall Protected Steel Tanks

Piping – 18% Double-wall piping –9% Double-Wall Fiberglass Piping

4

15

Single-Wall 10 Protected Steel Piping

24 Double-Wall Thermoplastic Flexible Piping

Single-Wall Fiberglass Piping

3 Other Single-Wall Pipe – (Copper)

Sources - >2003 Piping 22% Overfills/Spills/ Spill Buckets 39%

Dispensers 18% Submersible Turbine Pumps 4%

Other 13%

Tanks 10%

Sources -