Table of Contents
- Case Study Intro
- How does an agency like the MWRA benefit from a Tank Management Program?
- What is covered in the MWRA Storage Tank Compliance Program?
- Initial Monthly Walkthrough Inspection Results
- Cost Effective Tank Repair and Maintenance Solutions
- Staying on Top of Storage Tank Regulation Changes
- Responding to Emergencies
- Third Party Inspections
- Testimonial from the MWRA Property Manager
Fuel Dispensers at MWRA Deer Island
Massachusetts Water Resources Authority (MWRA) is a public authority that provides wholesale water and sewer services to 2.5 million people and more than 5,500 large industrial users in 61 metropolitan Boston communities. CommTank was awarded a 3-year contract in July 2014 to provide fuel tank inspection and maintenance services to the MWRA for their aboveground and underground storage tanks. This contract includes services such as third party inspections, annual preventative maintenance, tank testing and calibration, emergency on-call and non-emergency on-call personnel. CommTank performed repair services for automatic tank gauges, tank management systems, and underground and aboveground fuel storage tanks, as well as provided replacement parts.
The MWRA has 32 locations with 47 storage tanks. The sites vary from fuel dispensing facilities that provide gas to staff vehicles, drinking water and wastewater pump stations, and a sewage treatment plant at Deer Island. Of the 32 MWRA locations, 26 required monthly walk-through inspections as part of the underground storage tank (UST) maintenance program.
Equipment differences such as, age of installation, brand of manufacturer and the material used to store liquids, create a logistical challenge for facility maintenance managers. For example, there are fewer prerequisites for testing heating systems and generator fuel storage systems, than there are for gasoline dispensing systems. Underground storage tanks have more regulatory requirements as compared to aboveground storage tanks. Six distinctive brands of leak detection systems monitor the MWRA storage tanks and four underground tanks are oil water separator systems. These complexities and the EPA requirement to maintain UST operator training provided incentive for the MWRA to implement a storage tank management program.
The MWRA contract covers forty underground and seven aboveground storage tanks and ten gasoline or diesel fuel dispensers. A monthly walk-through inspection, overfill protection testing, tank leak detection testing and fuel testing are components common to all MWRA locations with additional components customized to the facility and equipment.
Other services we provided for this tank management program included:
- Preventative maintenance
- Record keeping
- Class C Operator Training
- UST tightness testing
- Line tightness testing
- Stage I testing,
- Automatic tank gauge certification
- Replacement parts
This storage tank compliance program prepared the MWRA facilities for the tri-annual compliance certification process as required by MassDEP CMR 310 CMR 80.00 and covered in this compliance assistance guide.
During the first year of inspections performed for the MWRA compliance program we found 23 of the 26 sites had minor items that needed correction. The initial walkthrough inspections for the underground tanks found spill bucket covers for numerous tanks were damaged or missing. This is a common issue when spill bucket sumps are the older style and can be removed by plows performing snow removal. The initial walkthrough also made recommendations to deploy emergency spill kits at facilities where they were found to be not present. Spill kits are recommended to contain and mitigate fuel discharges and are required at facilities that have EPA Spill Prevention Control and Countermeasure (SPCC) Plans. A few tank sumps had cracks or corrosion and sensors did not trigger alarms when tested for fluids.
CommTank's inspector tracing the source of an aboveground diesel tank leak.
False alarms are another issue we encountered. Sometimes it is triggered by water entering a piping sump that doesn’t have a proper gasket. A failed sensor could also set off an audible and visual alarm. We found tanks that had disconnected or faulty sensors which required further investigation to return them to full function.
Make sure to set UST sump sensors to the correct level
Underground storage tanks are located in corrosive environments due to the nature of underground installations. They are in constant contact with soil, water and concrete which present a corrosive mix to steel products. This is why it’s important to stay on top of your underground storage tank maintenance. A tank compliance program will ensure your system is doing its job as a spill prevention countermeasure.
Through the monthly inspections CommTank’s project manager identified the storage systems issues, prioritized the problems based on recurrence (e.g. calls due to alarms) and proposed upgrades that would reduce the number of service calls and maximize the reliability of the system in a cost effective way. An example of a cost effective solution occurred at the DeLauri Pump Station. CommTank fielded numerous calls for alarms indicating fluid in the tank sump. UST piping sumps are designed to shed surface water and be water-tight but aren’t designed to be submerged. Soil had clogged the gravel around the sump resulting in poor drainage. CommTank’s knowledge of proper UST installation techniques enabled us to find an innovative long term solution which kept costs down. The repair involved removing the gravel and replacing it with new gravel, upgrading the sump and pouring a cement pad.
Setting the form with rebar for a new concrete pad
The new sump, manway and concrete pad
Massachusetts regulations for spill buckets and tank sumps were updated in 2015. All spill buckets and sumps (including dispenser sumps) have to be tested hydrostatically to confirm they hold fuel in the event of a release. During testing at the MWRA facilities six of the underground tanks failed the spill bucket integrity test. New spill buckets were ordered to replace the failed ones and upgraded when the facilities could be taken offline.
Regulations also changed in 2015 for Enhanced Vapor Recovery (EVR) and MassDEP now requires Stage I recovery systems at gasoline dispensing facilities instead of Stage II. Four MWRA facilities are affected by this regulation and were updated in 2013 to Stage I systems. The Stage I systems require weekly visual inspections that check for shear valves (shutoff valves that split off when a vehicle impacts the dispenser) defective hoses, p/v vent caps, obstructions to vapor holes and signs of fuel in the dispenser sumps. If these regulations are not followed accordingly, the MWRA could be subject to significant penalties. MWRA personnel trained by CommTank conduct these inspections to ensure the integrity of the Stage I systems and to ensure compliance with the MassDEP regulations.
The second requirement for Stage I systems is yearly component testing. CommTank’s certified technicians performed this test (US EPA Method 27) and confirmed the system achieves a 95% emissions reduction rate. The testing at each site varied based on the equipment installed. We keep records of each test and submit reports to the facility managers.
Vacuum test on tank recovery lines
Stage I vapor recovery returns gasoline vapors from the service station’s underground tank system back to the tanker truck during product delivery.
References - DEP Stage I and State II Vapor Recovery Amendments, 310 CMR 7.00, 7.03, 7.24, dated January 2, 2015
As part of the contract with the MWRA, CommTank is required to respond to emergencies within 2-hours. On September of 2015, one UST site had an indication of a leak, as reported by their automatic tank gauge. A CommTank technician responded and investigated the problem. The tank had a small amount of water in the interstitial space (the empty void between the inner tank wall that holds the fuel and the outer wall that is exposed to the soil) which required a pump out and resetting the sensor. Water accumulation in the interstitial space can occur due to the buildup of condensation and is considered a false alarm.
On a second occasion, the sensor indicated water present and triggered the alarm. CommTank recommended a tank tightness test to prove the integrity of the outer tank wall. The MWRA approved the test recommendation and CommTank’s technicians performed the test which showed the tank was sound. We then ordered and replaced the interstitial space sensor and solved the false alarm issue.
Water being removed from tank sump
In the first year of the contract, CommTank responded to 31 alarm reports, but by the third year through the diligent efforts of CommTank and MWRA to identify and rectify deficiencies in the tank systems the number had been reduced to 16.
Third Party Inspections are required tri-annually for underground storage tanks. The MWRA’s inspection was due 2 years into the contract with CommTank. A Third Party inspector evaluated the 26 underground storage tank facilities over a two month span in late 2016 and early 2017. No compliance issues were noted. Any faulty equipment had been identified and corrected by CommTank during monthly walkthrough inspections; each UST system had its monthly inspection reports, certifications, permits, and proof of financial responsibility ready for the third party inspector. The benefits of having a tank management program are evident in the ease and successful completion of a Third Party Inspection.
Massachusetts Water Resources Authority pump station
‘CommTank has had an underground storage tank maintenance and inspection contract with the MWRA since July 2014. During this time period they have provided a superior and cost effective level of service. We are highly satisfied with their work and look forward to working with them into the future.’
John Nelson, P.G.
Environmental Manager: Real Property & Environmental Management Dept.
Massachusetts Water Resources Authority
2 Griffin Way, Chelsea, MA 02150
"Far, far exceeded my expectations for what could have been a messy and smelly job."
"All at Comm Tank made a very stressful situation for us more than manageable. The men who came to do the work were always on time, extremely polite, and hardworking."
"In 34 minutes they achieved the removal without doing any cutting inside my home! Seeing is believing, which is why I sent you, today, the photos taken of their remarkable effort."
"Recently we hired your company Comm Tank to remove an underground oil storage tank buried in our front yard for many years. We also asked you to install a new aboveground oil storage tank next to our house."
William J. Lewis.
"They left the area cleaner than they found it. They were very friendly and fully explained how the tank was to be cut and removed."
"I would recommend Commtank to anyone who needs an oil tank removed. The price for such great service was very reasonable. Truly a good experience for me and my family."
"In the 40 years that I have lived in my house I have never had anyone do so much work, rip up so much sod yet leave everything in such a clean, neat and apparently undisturbed state."
"I want to thank you all for your excellent customer service and for going above and beyond the call of duty, to get my leaky oil tank problem resolved in time to sell my father's house."
"Paul’s recommendation along with the comfort level I felt dealing with your team made my decision to choose CommTank and easy one. Should I ever hear of anyone in need of a new oil tank I would recommend CommTank without hesitation."
"We have used CommTank now for inspections and service for the last two years. We have found the CommTank team nothing less than professional, knowledgeable and reliable."
"I do mean all of them…you could be proud of them and know that they represent your company in a very professional manner. In today’s world, you very rarely see this."
Billl and Barbara Clough.
"The project was on time, under budget, and everyone connected with the project was very easy to work with, both people on-site and in the office. "
Town of Southborough, Ma
"I want to thank you for the excellent work you and your crew have done at my station."
"I am emailing you with this word of “Thanks” to Comm Tank for one of the most professional companies I have used in quite sometime."
"When I called for an estimate, Margie was very informative and one of the reasons I chose CommTank to do the work."
Jack E. Meyer, M.D..
"I had an oil tank removed yesterday, and the whole operation could not have gone more smoothly."
"What could have been a stressful situation actually went smoothly without any issues or surprises. I would recommend CommTank in a heart beat to anyone in need of their services."
Scott E. Lechter.
"There were many steps throughout the process and at every step I was very well informed. The scheduling, coordination and communication was simply outstanding."
"I want to thank you for your work in the oil tank removal at my mother’s house in Walpole."
"Except for the oil smell for a while, you really couldn't tell that the work had been done; EVERYTHING was neat & tidy and cleaned up both inside and out."
"Thanks for your help and the customer service that CommTank provided."
North Reading, Ma
"Your employees did a nice job and were a credit to your company in their professional work and attitude."
"Thank you for doing a very nice job!"
Prides Crossing, MA
"Your crew just left my site and they are wonderful, clean, great, and nice!"
"I would certainly recommend your company."
"These two excellent employees came early, at 7:15 a.m. Which is very appreciated by us, clients that have to leave for our jobs."
"They patched the holes left from removing the fill and vent lines like pros - I did not expect this level of service."
"Kim and I are very happy to have found you!"
"We want to tank your for a job well done while removing the underground oil tank."
"I wanted to thank you for a great job on the installation of the new fuel dispenser."
"Thank you for your donation of 200+ gallons of fuel through your CommTank Cares Program to St. Clement Parish Schools. Your generosity is certainly a help to our schools and parish."
Reverend Paulo Cumin.
"just want to express my appreciation for the excellent service that was provide to me in the removing of our 1,000 gallon underground oil tank."
"What I think I’ll never forget was how clean the basement was after the two men had removed the contaminated soil from our house. It had never looked like that!"
"Early this month your company removed my almost 40-year-old tank from my basement and installed a Roth Tank. I was extremely pleased with the results and with the crew that did the work."
"It was neat and clean and they left the area spotless. The gentleman who came back to inspect the job was kind and courteous."
"The City is extremely grateful to CommTank for its assistance in this cleanup. We believe we made a very wise choice in the selection of CommTank. Please feel free to use me as a reference for your team's pursuit of other environmental work."
Thomas G. Ambrosino.
"She called to brag about how professional the service was, and how clean and precise the installation was."
"We really appreciate the responsiveness to what was a worrying situation and the two men who performed the work were true professionals."
"This company is the best. The price was very reasonable, better than anyone else I contacted, about $300.00 less,"
"I had my oil tank and boiler removed from my home. Comm Tank showed up on time and finished the job quickly and neatly."
"I want to thank CommTank for the wonderful job that your crew did yesterday while removing and installing my oil tank."
"Thanks so much for getting your guys out here so quickly to take care of the issue. While they could not tell exactly what caused the seepage, they ended up replacing the red connector with the fill gauge to be safe."
"There were two crews on separate days that did a great job and were very knowledgeable about their job and company."
"As for me the customer, I am very pleased on the workmanship that was performed, and I would recommend ComTank to anyone that needs a new tank."
"Your workers were out at my house in Wayland last week and did a fantastic job removing the oil tank from my basement."
"The quality of their craftsmanship is buzzworthy, the work surpassed my expectations."
"They showed up on time, were extraordinarily efficient and neat, provided a comprehensive removal, and were very courteous in all our dealings."
John P Senko.
"You and your entire on-site crew, including Santiago and Carlos, all have been first-rate and first-class."
"Thank you for your competence and professionalism, your cheerful and hard-working staff, your expertise with regulations/compliance issues, and for referring us to Tommasino & Tommasino in Boston."
Richard and Kristen Henshaw.
"Please note that this appreciation comes from a person managing construction for clients for some forty years."
"Excellent work so far. We wish these guys were on all three Boston projects."
Peachtree Corners, GA
"He will refer us to anyone and will definitely be using our services again."
"Please let the crew know that I really appreciate the hard work and professionalism."
"I spoke to Cindy the other day and reiterated to her about how happy we were with our experience."
"The thorough explanation of what was to be done was excellent."
"During this past summer I had an underground oil tank removed and replaced with an indoor Roth oil tank, and was exceptionally pleased with the service."
"In my opinion they were very professional and courteous."
Mary Louise Thrower.
"Thanks again to you and your team for the high level of workmanship and customer performance you provided."
"Your company has been most professional, timely, and informative!"
"This was our first experience with your company and we were very pleased from start to finish."
"Your crew were great to work with and did a great job, although very hot out there, they continued on with no complaints."
"All of our clients are more than satisfied with the quality of CommTanks installations and LEO is as well."
"It was a pleasure having them work at my house."
"They quickly went to work and solved the problem. As worried as I was, Luis made me feel that everything was going to be ok. Luis was always there no matter how many times I called."
Jeffery J. Graham.
New Bedford, MA
"We were so pleased with the removal of the old furnace."
"They tore down part of a wall, shoveled, removed my old tank and replaced it with a new tank, also gave me some oil."
"They were courteous and professional, timely and completed everything as well as anyone could have asked."
"I have dealt with contractors before and was very impressed with your crew."
"I would hope I would never have to have a UST removed again, but if I did, you would be the first people I would call."
"They left the basement much cleaner than when they started the job."
"Kevin's response and his team’s effort to help contain and cleanup a small spill were some of the best I have seen in my 40+ years in the petroleum industry."
"The technicians were outstanding. We needed 3 tanks removed from our basement."
"Kevin Hoag and Nelson were outstanding, they showed at 8:00 AM sharp, they were very professional, explaining all steps, very polite, their work was perfect."
"CommTank just finished the UST removal job and the customer is absolutely delighted."
"Amazed that this level of customer service still exists in this day and age!!"
Jamaica Plain, Ma
"Great job, completed on time, very aware of the Safety of our tenants."
Deborah M. McClory.
"Came when they said and did what they said quicker than I thought and left the cellar clean all at a reasonable price."
"I also commend Luis Diaz on his pleasant, informative phone manner when we first spoke and at the time of the site exploration. His handing of the situation convinced me to go with CommTank."
Newton Centre, Ma
"The professionalism and courtesy with which you and your crew handled this situation far exceeded my expectations and that of my customer."
"I will recommend your company to my colleagues and clients."
"From the moment I contacted Comm Tank, it was nothing but a positive experience."