Operation, Maintenance, and Inspection of UST System Release Detection and Prevention Equipment

Transcription

1 Operation, Maintenance, and Inspection of UST System Release Detection and Prevention Equipment

2 Objectives Raise awareness of remote monitoring systems capabilities o Methods of connections to ATGs o Difference between technicians connecting on-site vs. remote services Why storage tank owners/operators select remote monitoring systems o Ability to store all storage tank documentation in a single location Multiple parties can access the same information Compliance, construction, finance o View fuel levels and dispatch fuel replenishment o Monitor unmanned facilities o Program in-tank and line tests remotely Challenges o Maintaining connection to ATGs o ATG equipment changes Regulatory Compliance

3 ATG Connection There are differences between how technicians and Remote Monitoring services connect to an ATG. Technicians o Technicians will connect a laptop via serial or Ethernet (TCP/IP) port on the ATG while on-site. o Technicians use custom commands to change the ATG programming. Remote Monitoring services o Remote Monitoring services will use a serial, static IP, or wireless connection to the ATG. This connection must be maintained. o Remote Monitoring services will use information commands only (I commands) to retrieve ATG data.

4 Technician ATG Access Direct connection to the ATG at the site Telnet ATG Manufacturers software Proprietary software

5 Remote Monitoring ATG Connections ATG connections are made via phone, serial, Ethernet (TCP/IP) boards in the ATG. Alternatives are custom serial to Ethernet and wireless connections.

6 Remote Monitoring ATG Connection Ability to connect and collect data from different ATG devices through one management system. Client has 1 INCON out of 20+ sites Client has both ASTs and USTs

7 Multiple ATG Connections Primary and backup connections Cellular and Ethernet Serial and Ethernet

8 Remote Monitoring Benefits Release Detection Sensor/probe status reports daily In-tank testing reports daily/weekly/monthly Alarms 24/7 response to alarms via and/or phone Remote alarm resolution ATG testing Programming in-tank and PLLD testing Fuel Levels Cost savings via on-demand replenishment Unmanned facilities 24/7 monitoring of site ATG conditions Recordkeeping Tracking testing, permits, insurance, certificates, and training

9 Release Detection Release Detection Sensor/probe status reports o Many ATGs print a daily sensor status report, and the DOS command only pulls the daily report. There is no available command to pull a monthly status report. In-Tank test reports o ATGs store the last 12 months of passing results, but what if there is a power failure? How do you prove compliance in states that require months? Multi-site Release Detection Client s with large portfolios can review all their release detection results, regardless of the method, in one location. Proactive Release Detection Review site release detection on the 15 th of the month for non-passing results. Notify site maintenance of issue so that it can be resolved, and passing results obtained.

10 Release Detection Recordkeeping The old way

11 Release Detection Recordkeeping Remote Monitoring services way

12 Alarm Management Current alarms/warnings and cleared status Through either the ATG auto-dial feature or proprietary programming, alarms are transmitted to the Remote Monitoring service. Alarm management includes documenting the resolution for leak-indicative alarms (in-tank test fail, sensor fuel alarm). Alarm History Reports History of alarms by site, sensor, alarm category, and documentation of the actions taken to clear an alarm. Ability to provide clients with alarm trends reports. 24/7 Alarm Response Ability to dispatch alarms via to maintenance or client.

13 APEC Alarm History Report

14 APEC Alarm Trends

15 ATG Test Programming Remote programming of in-tank, and leak detector testing One-time, or recurring testing can be programmed remotely. Advise clients with in-tank testing to perform the test weekly. Remote diagnosis of PLLD, and in-tank testing failures Ability to review fuel level history to determine if there is enough fuel for an in-tank test. Contact site to confirm cause and remotely access the ATG to start testing.

16 Fuel Levels Fuel inventories are a significant concern for both the dealer, the operator, and delivery truck dispatch. The operator wants to have enough fuel inventory to meet demand, but not tie up assets by having too much fuel in the tanks. The dealer wants to be able to purchase a specific amount of fuel at once to get the best price. The delivery dispatch wants to be able to dispatch a truck to have limited stops for efficiency. Remote Monitoring services can provide current fuel levels as often as requested for all client facilities. Ability to monitor both a typical ATG or tank inventory-only gauges, and push a consolidated report to the client or delivery dispatch. Very important for clients with both ASTs and USTs.

17 APEC Inventory Report

18 Unmanned Facilities Unmanned facilities have been deferred from the federal UST regulations. Fuel levels and alarm conditions are still a priority for unmanned facilities. Remote Monitoring services allow clients to access the unmanned facility ATG without requiring an on-site visit. Ability to remotely diagnose and troubleshoot issues before dispatching maintenance vendor to remote sites. The most common issue is establishing and maintaining a data connection to the unmanned facility. Often in remote locations with no phone or Ethernet available. Remote Monitoring services can provide wireless modem to site ATG.

19 Remote Access Sites that may be ideal for Remote Monitoring services: Emergency generator systems Remote sites o Cell phone towers Unmanned fuel retailers Where allowed by regulation Fleet fueling facilities Personnel on-site for limited time each day

20 Recordkeeping One location for all the required information by UST regulations, and the ability to the information to the facility, regulator, or others. Testing Results Permits Training Certificates Financial Responsibility Reports Upcoming testing, permit renewals, training required, etc. Release detection by all of client s sites Alarm history, and alarm trends Site construction details (which sites have OPW 71-SO?) Liability reduction For every day that we are connected to a site, we have the sensor status, in-tank test, and PLLD test results.

21 Facility Details One location for all details of the client AST and UST systems.

22 APEC Event Tracker

23 APEC Activity Log

24 Challenges Maintaining a connection to the ATG Phone/fax lines are often used by multiple pieces of equipment at a facility. Finding the right moment where the phone line is unused can be difficult. Ethernet cables are often used by site employees. It s late, they want to watch a movie on their laptop, and it s free internet! o IP addresses must be static, not on-demand (DHCP). If the IP address to the ATG changes, the Remote Monitoring service will not be able to connect to the ATG. Assumption by site personnel that someone else is in charge of the ATG. Remote Monitoring services work with site personnel to diagnose, and resolve issues. Site personnel are the eyes for Remote Monitoring services. If there is a PLLD shutdown, we need to know whether there s a reason that the ATG closed the line. Car vs. dispenser, testing, etc.

25 Challenges, cont. Keeping current with ATGs new models, new features. Remote Monitoring services operate in an undefined area of storage tank compliance Release detection methods must be approved by the USEPA. ATG and sensors/probes must be reviewed by NWGLDE. There is no review or regulatory requirement for reports or data management provided by Remote Monitoring services. The California State Water Resources Control Board is the only agency to have a certification process for Remote Monitoring services. Requires certification by an ICC UST Technician that the commands cannot make changes to the ATG programming, or That ICC UST Technicians use any program that contains commands that can make changes. How do you enforce this?

26 Future Goals Remote Monitoring is only one piece of comprehensive storage tank compliance management. Inspection tracker Several states now require monthly or quarterly documented visual inspections. Work with 3 rd party inspection firms or client personnel to complete inspections, log and track deficiencies by equipment, region, etc. for clients. Environmental Plans Emergency Personnel and Community Right-to-Know Act reporting Spill Prevention, Control and Countermeasure Plans Stormwater Pollution Prevention Plans

27 Thank you Jon M. Marinas JMM Global Headquarters 2496 Technology Drive Elgin IL, USA Phone: Website: