Lexington DPW Storage Tank Management Program
CommTank provides Underground Storage Tank (UST) Operator A & B services, Stage I Vapor Recovery Testing, ATG Recertification, Line and Leak Detector Testing, Third Party Inspections and preventative maintenance services for the Town of Lexington Department of Public Works (DPW). The following are the detailed components of the Storage Tank Management Program:
Underground Storage Tank A&B Operator
We perform monthly visits to review leak detection system documents for the UST and components and to insure compliance with Massachusetts 310 CMR 80. A monthly report of our findings and recommendations is supplied to the Town of Lexington’s Information Coordinator for record keeping.
Stage I Vapor Recovery Testing
CommTank’s certified technicians confirm the system achieves a 95% emissions reduction by testing the components as required by US EPA Method 27. We submit records of each test to the facility manager at the tests completion.
The Automatic Tank Gauging (ATG) system is a wall mounted unit that monitors the tank levels, fuel consumption, interstitial space, and overfill alarms. CommTank tests, inspects and calibrates the ATG system according to manufacturing standards and produces a report that covers the following components:
- In-Tank Testing
- Interstitial Sensors
- Containment Sensors
- Dispenser Sensors
Re-certifying the ATG ensures the monitoring system meets the manufacturing specifications of yearly testing for warranty coverage.
Line and Leak Detector Testing
Release detection is required by EPA regulations and the methods vary based on the installation date of the regulated tank. The three basic requirements for Underground Storage Tank leak detection are:
- Piping that contains fuel must have some type of leak detection equipment
- The installation, operation, maintenance and calibration must adhere to the manufactures instructions.
- Sections 280.43 and 280.44 of the EPA UST regulations must be met by the detection system
CommTank provides training to the Lexington DPW staff to ensure that they operate and maintain their system properly. We also perform the annual recertification tests required by the manufacturer (Veeder-Root). Even though line leak detection equipment has automatic test capabilities, a manual test must be performed yearly. This ensures the detection equipment works by physically activating floats and valves. CommTank’s technicians adjust the pressure and leak rates to simulate a leak and verify the system is operating to Veeder-Root’s specifications.
Third Party Inspections
The U.S. EPA mandates that each facility with regulated underground storage tanks have a Third Party Inspection performed every 3 years after the initial inspection. The Third Party Inspector examines the system and inspects the following components:
- Secondary containment (Interstitial Space Monitoring System) is in place and operational. Ensure it is free of water, fuel or solid material (sand or soil).
- Checks that the spill prevention device (spill bucket) is up to code and performing to the manufacturer’s specifications
- Corrosion protection (as required by the tank type and manufacturer)
- Verifies the Overfill Prevention Device (automatic shut-off valve, float or flapper, high level alarm ) is present and functioning properly
- Release detection for the UST and fuel piping is operating and meets state and federal guidelines. Verify the electronic leak monitoring/detection system has been calibrated according to the manufacturer’s standard.
The Third Party inspector also verifies that the owner has the proper documents to operate the UST at his facility. These documents include:
- License to operate and store the regulated liquid
- Permit to maintain the system (Required by 527 CMR 9.00)
- UST registration form (FP-290)
- Financial Responsibility (Required by 310 CMR 80.00)
- Release reporting records
- UST closure records