Interpretation, next step planning, customer prevention and maintenance
Fuel oil dealers are responding to changes mainly in response to competitive market forces. It was a COD districtor at the beginning, it was a gas company, we responded to each on the spot. Now that the afflicted areas of underground tanks are getting more violent, dealers will receive a buffet with the momentum that will affect the market again. Do you promote a program to derail threats as to whether to respond as before? In New York State and New Jersey, home owners' environmental protection program
It is a valuable tool to set a precedent and prevent gas shift, but more tools are necessary, especially to prevent leakage of uncontrollable accounts that occur over time
Property trading.
In the early 1980's, I was a vice president and founder of Annis Fuel Oil Service (AFOS), I recognized the underground oil tank as an area of opportunity. With the revision of New Jersey 's Hazardous Substance Storage Law and Outflow Prevention Law, tank work began to overlap with environmental science. The chemistry of the university for the past 4 years has made good results. Spinning off ANCO environment I was faithful to the beginning of my oil industry in 1991. As a small oil dealer, I
Threat UST hysterical pose. At the diplomatic site, we sell UST service to local fuel dealers competing with my family's oil company. Instinct says to deny or minimize the UST problem. However, the storm of the distant environment is approaching and we have to deal with it. we
The monetary interests of customers are at stake and we are seeking leadership. Fuel dealers need to deal with public relations damage resulting from underground tank leaks, learn how to choose an appropriate tank test, define the true negative impact of oil tank breakage, and finally find a solution . I hope that the data presented here will be useful in these areas and will prevent the loss of petroleum customers to other forms of fuel at the time of real estate transfers. As my company is mainly operated in New Jersey, there are many references to the regulation of the New Jersey State Environmental Protection Agency (NJDEP). These regulations may be reflected by similar regulations in other states. For specific regulations governing your area, please check your State Environment Protection Agency.
Misinformation
Gas companies have led the marketing campaign that insists that the heat of oil causes underground pollution. Our observation supports the opposite conclusion. Statistically, the improved project will include an obsolete tank or an improperly closed tank. Because the owner's insurance contract does not pay most of the UST pollution claims, leakage of the owner of the tank, turned into gas heat, has a greater bond today than people who lived in oil. However, where the home owner of the gas is plagued by the repair bill, the oil industry has a negative decline. To win the public relations game, the fuel industry must try to divert the problem. Until an underground tank that redirects the emphasis of oil heating, take an active position.
Fuel oil accounts are most vulnerable at the time of real estate transactions. Tank testing and field certification are becoming more common. It is caused by debt concerns or due diligence. Audit requirements, contrary to innocent purchasers, buyer attorneys will ensure the right of testing around customers' oil tanks. Due to the misunderstanding of the masses, this mechanism will continue to defeat the heat of oil.
Know your enemies
A dealer recently said to the lawyers: a gas company, a gas heating contractor, a real estate agent, a lawyer such as a yank tanker had said that the corrosion of the voice to the true silence enemy, a high pH The combination of soil and high water table enables high ion exchange rate with the tank and as a result the electrochemical reaction concentrates on the largest point of the electric conductivity Conductive mineral content in contact with the tank or Particles with structural debris complete the corrosion circuit, but over time this reaction will dissolve the holes in the tank.
Looking at the history of environmental regulations, the 1977 Federal Clean Water Act is the foundation. This law focused on industrial polluters. In 1984, the New Jersey Environment Cleaning Liability Law (ECRA) was established,
Regulatory-led responsibility made the existence of UST the head of industrial owners. This was a distant thunder of the disaster of the UST today. Strict industrial environmental regulations have spread to the residential environment.
In June 1993, ECRA was revised and the ISRA of the Industrial Zone Recovery Act was revised. Many positive changes made regulations more "user friendly" and sympathized with the creation of spill funds. However, although these changes were rarely noticed, we introduced principles that greatly influence all current and future real estate owners in New Jersey, with changes that accompany spill compensation and management law (spill method) became. New principles promulgate it Future owners of contaminated property will be responsible for the pollution they did not cause . Potentially devastating words of this amendment will allow buyers to take responsibility for emissions of hazardous substances unless they can meet certain criteria.
- They will have acquired property by inheritance.
- They purchased the property after the discharge occurred;
- Lack of knowledge that harmful substances leaked at the time of acquisition.
- It is not involved in managing risky assets that flowed out before acquisition.
- Notify the NJDEP at the actual discovery of the discharge.
In order to prove that the new owner does not need to know the emissions of the harmful property of the real estate, the acquiring party must "have carried out all appropriate investigations on previous ownership and use at the time of acquisition" All appropriate inquiries "require preliminary assessment and field survey if necessary. In the case of underground storage tanks, in the short term of the soil test, we satisfy the appropriate question "threshold" and regard the damaged purchaser as "innocent purchaser". "This concept is responsible for buyers
Abandonment parties not involved in real estate transactions. Thanks to regulation and traditional fashion, buyers tried to be careful, but the tank test is here.
Choose the right tank test
Suitable tests are a function of tank conditions, location conditions and global objectives. The verifiability and timeliness of the results are additional test selection criteria. Limitations of the test, conditions of potential false positives and false negatives are discussed after the introduction of each technique.
For an overview of tank test methodology, ANCO's UST LINE *, Issue # 4. "Which tank test method is best?" The purpose of the tank test is to protect the buyer from past leaks and to protect the seller due to problems that did not exist when the seller sold. In order to accomplish these goals, we ask for a single answer: did the problem tank leak out and create an environmental problem? In other words, is the site contaminated?
When choosing a test to answer this question, the first concern is accurate results and verifiability. Scheduling simplification, quick results and cost are also important. Finally, considering soil stratigraphy, it is necessary to have a test that can be applied to appropriate situations that supplement the situation in the field.
The best test option meets all or most of the objectives of accuracy, verifiability, speed and cost.
The tank test has three main categories of liquid, air and soil test. The first two are in-tank tests incorporating innovative computer-based equipment that measures the rate of loss when reagents, liquids, or gases leak out of the tank. This is a disadvantage of in-tank testing. Does the buyer acknowledge there is a possibility of leakage? Probably not. However, NJDEP is. To compensate for the specific limitations of these tests, NJDEP
We set a threshold of 0.05 gallon pass / fail leakage per hour, below which the tank "legally" passes the test. However, this "acceptable" leak rate is 1.2 gallons per day, or 438 gallons per year. This is unacceptable to most buyers.
for Liquid test , Or in the volume test, the tank must be filled with oil in the neck of the filling pipe. Only when the oil level decreases at a rate exceeding 0.05 gallons per hour, a slight change is observed and the tank fails.
- advantage: This test does not cause disturbance of the surface.
- Disadvantage: A false positive result indicating a leak is not unusual under the condition that the thread on the filling pipe is lost. Fuel supply must be tightly adjusted with the performance of the tank test itself. This requires additional expenses. To make matters worse, if there is a leak in the tank, the test itself will drain more dirt.
- Verifiability: In addition to reviewing test data, verification is impossible without a complete retest.
In the vacuum test, plug all the pipes into the tank, apply the vacuum, then listen to the leak sound with the hydrophone.
The tracer test involves injecting a noble gas isotope into a tank and using a sensor located outside the tank to detect leakage of the noble gas. The result can take up to 10 days to process due to the gas transfer period: clay soil slows the moving speed.
- advantage: Vacuum and tracer tests are easy to calibrate, there is no surface turbulence and piping can be tested.
- Disadvantage: The result of false positives due to the loss of fittings is not uncommon and the volume of these tests uses the 0.05 gallon / hour standard.
- Verifiability: In addition to reviewing the data, verification is only possible with a complete retest.
The third category, soil test, directly measures the amount of oil that has already leaked and answers directly to the central question easily and cost-effectively.
In this test, the soil sample is withdrawn from around the tank at a depth of 6 "- 12" deeper than the bottom of the tank. These samples are tested for petroleum hydrocarbons. Results are immediately available. Several methods involve visually checking for signs of corrosion and digging the hand at the top of the tank to reasonably position the ends of the tank. Obviously, the closer the sample is to the tank, the more accurate the representation of the underlying soil condition. The analysis result is checked against the action level of NJDEP to identify the problem.
- advantage: This is a simple test, not an electronic instrumentation. It detects oil spill from any source, including previously removed leak tanks and overfill. Contamination by overfilling is easily distinguished from deeper contamination due to tank breakage. This method is applicable to underground tanks whether they are active (in use) or out of service. Even previously closed tanks can be tested to determine whether the tank leaked before closure and whether the leak was not remedied.
- Disadvantage: Soil test disturbs the soil. This is an out-of-tank test asking for the effect of leakage.
- Verifiability: You can leave a hole of diameter 1 1/2 "open, making independent sample collection easier.
After receiving the test results, what should I do if there is a doubt of leakage or pollution is confirmed? The next step is to determine whether the test results are valid and whether the site is contaminated. Since we can not tell this only by ship test, we need to conduct soil test. By incorporating it into this test, it is possible to inspect tanks and piping, eliminating the possibility of false positives.
When the test is deemed valid, perform a quantitative analysis to plan the amount of soil and / or tank removal and site repair.
Quantitative analysis compares the level with the applicable action level. Removal of the tank is unreasonably necessary if the level exceeds state regulations. However, when a question is asked, the level of action loses its meaning. Why is oil 12 inches under the tank? Low levels are alleged to be normal, but low levels may be an indication of imminent total tank failure. (NJDEP may tolerate up to 10,000 ppm TPHC) The recommended value of this dealer has risen above instinct not shown In this case, dealer's concern for customers Do not make small problems a big problem It was.
plan
All disposal facilities require analysis of various laboratories. The standard turnaround time for these tests is 2 to 3 weeks. This is also a typical lead time between shrinkage of tank removal and actual mobilization for removal. The work should be adjusted so that the exam is completed before mobilization. Such a plan speeds up the cleanup and shortens the project time by about three weeks.
Tank removal, soil drilling and disposal can be done as one operation by securing in advance soil remediation contaminated with approved disposal facility in advance. This eliminates the need to return to the site later to remove contaminated soil. This is very important in the shortening of working hours and winter season so that excavated soil does not freeze to become a solid mass. This single working approach requires less cost than tank removal - soil drilling - storage and then needs to return to load substitutes.
Therefore, the most immediate route toward rapid purification requires soil testing.
Prevention
So far, I explained the procedure following the failure of the tank test. Tank tests are generally done by buyers before real estate transfers, so oil accounts are now at risk of being lost. What can be done to prevent being subject to tank test first?
The first choice is to cooperate with the seller before listing the property and converting that account into gas. This is the poorest choice for our industry. Fast gas shift sale forever loses that account. Historically, this choice left the nationality of the tank that was inappropriately closed to our industry. These will eventually become brighter and the association will defuse the fuel oil's name. Inappropriately closed tanks will continue to be an important publicity issue than active UST as there is no direct financial support for hidden pollution in case of leakage.
Let's change the first choice by restricting the gas conversion service offer. Furthermore, when closing an underground tank (accompanying gas shift), it is possible to drain hidden pollution at that point by providing only tank removal and soil survey. If problems are found, financial difficulties will be the result immediately after the decision to convert to gas. This hardship is less sympathetic than what an innocent property owner who found a problem succeeded later endured. This approach changes the table of ruthless portraits of oil and gas markets as polluting gases.
My second recommendation is that oil dealers selectively prompt customers to move from old single wall steel underground tanks to underground tanks, ground tanks, or double walled tanks. This must be done with great delicacy and finesse. It is necessary to restore the situation of the underground tank from & # 39; No problem & # 39; Problem of event of & # 39; It is necessary to take action before tank starts to leak. This minimizes the possibility of cost overruns and maximizes customer praise.
One approach that has already been implemented by some fuel oil distributors is the selective tank change program. However, if it is physically possible to install a 275 gallon tank, the installation of UST closure and 275 should be at least 35% cheaper than gas conversation. The dealer presents a financing plan, realizes this approach at affordable prices, and maintains a petroleum account. The project cost must be in the range of $ 1,800 to $ 2,000. With a 12 month non-interest loan system, payment of 150 to 167 dollars per month should be affordable.
In a nutshell, by preventing the oil tank test from failing in the first place, it is possible to prevent customers from failing the underground oil tank test. Eliminate tanks, change tanks, take a positive attitude, and prevent physical laws inevitably condemn him.
To be honest, I believe that the limitation of steel UST is clarified, and by offering an affordable solution quickly, I believe it is as much as my own for the financial welfare of the customer. It is similar to automobile recall for failed components. It is better to start a recall than to defend a lawsuit. In our case, it is better to take a more aggressive solution than to protect the name of fuel oil as a pollutant.
questions and answers
Question: What is the most popular way to close a tank?
answer: Regulatory Gazettes 88-3 and 91-4 mandate an acceptable closure method. These methods fall into two categories: in-place closure (aka abandonment) and complete deletion. UST line # 5 * We deal with selection of removal and selection of inside closure and recommend the latter as long as dirt under the tank is tested. this UST line * Introduces the concept of perfection. This is a big concern of home buyers. This concept applies to each closure method specified in Bulletin 91-4.
Done Level It is a measure of thorough employment in both environmental problems and future responsibilities. This thoroughness or integrity criterion has become an important factor determining the best approach to cope with the situation of certain underground storage tanks.
In terms of completeness, removal is best suited, and then the open tank is closed.
Removal pair In-place closure . Definitely the most thorough work will be done when the tank is completely removed. However, removing the tank consumes a lot of equipment, so it costs more than the in-place closure. If the completed deck or sidewalk is above or near the tank area, it is a very invasive procedure. Surface repair makes jobs more complicated and increases costs.
When you remove the tank, you need to measure the cost against the completion level. Are the homeowners planning to sell the house? The sealed tank remaining on the ground can become an obstacle. There has been no longer a day when I could just state that the tank was closed. Today, the seller concluded that the technology used to close the tank fulfilled the intent of Bulletin 88-3, and especially critically, The tank is not leaking . Removal of the tank provides the highest level of completion as the tank has been completely eliminated.
In-place closure technology falls into two categories: injecting concrete slurry or polyurethane foam under the filling pipe and pouring sand or gravel into a large opening. The former is completely harmless and the latter needs to dig his hands at the top of the tank, so you can actually enter the ship 2 & # 39; 2 & # 39; The cost of each approach is nearly the same. However, thoroughly it is possible to completely clean the tank from sludge and residue, and it is a far more complete approach to entering the tank because it allows leakage inspection inside.
* UST line This is the newsletter published monthly by Mark Anise, President of ANCO Environment Service Co., Ltd. For details, please visit ANCO's website. http://www.ancoenv.com .
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