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Emergency Power Generator UST Systems (NTC 2022 Preview)

Posted on Wednesday, August 31st, 2022 |

One of The Last Frontiers

This session at the National Tanks Conference will feature presentations from three speakers: Tim Smith with U.S. EPA Office of Underground Storage Tanks; Jonathan McRae with Nevada Division of Environmental Protection, Bureau of Corrective Action; and Gregory Young, past owner and President of Vaporless Manufacturing, Inc., now a Consultant to VMI Manufacturing LLC.

The first presentation will provide an overview of the federal UST requirements applicable to emergency power generator (EPG) UST systems. Smith will also highlight three EPA reference documents, published this May, specific to these UST systems:

  • Federal UST Requirements for Emergency Power Generator UST Systems (EPA 510-K-22-003).
  • In-Depth Discussion: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on Emergency Power Generator UST Systems (EPA 510-K-22-002).
  • Owner and Operator Introduction: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on EPG UST Systems (EPA 510-K-22-001).

The second presentation will discuss how many existing EPG UST systems were installed according to inconsistent design standards. In general, these systems are individualistic in nature. These systems have been designed essentially with an eye to the primary function of fuel delivery to the generator and not for ease of conducting a compliance inspection.

In this segment of the session, McRae will dissect several site layouts and show, from the perspective of an UST system compliance inspector, issues state UST implementing agencies can expect to encounter at these atypical sites. There are many challenges facing UST system owners, operators, and inspectors. However, through a collaborative process and positive attitude, future inspections at these sites can go smoothly and these systems can have few to no violations.

The final presentation will discuss several complexities that are inherent to EPG UST systems. Young will discuss ways to achieve proper line leak detection while effectively delivering fuel at these complex systems. He will explore ways of providing that unique balance of shutdown and alarm during regular monitoring and how to provide fuel when there are no other options.

Young will discuss certain key challenges encountered at EPG UST systems. These include many systems having an UST or AST with delivery pipe going underground only to enter a building to fuel gensets, or boilers, or both; the presence of system components such as several different types of pumps, filtration systems, and complex controls that include various valves; and concerns with low turnover of fuel. Attendees, including regulators, system design engineers, contractors, and technicians, will learn what to look for and how to test sites like these to ensure regulatory compliance and safe fuel delivery.

Cartoon of crowd gathered at tanks exhibit.