DLA Energy
Response to EPA - Release Detection Point Paper

Pursuant to the last meeting where you advised us that you were closer to the decision to remove the deferral of release detection for Airport Hydrant Fuel Distribution Systems and Field Constructed USTs and provided to us the Draft Deliberative Documents related to each, we have developed a brief response for your consideration.
Our overarching response to the removal of the deferral and your proposed release detection requirements is one of great concern.  We believe these performance requirements will have a gross cost impact, possibly increasing the required budget by 400%.  
In addition, in order to facilitate execution of your proposed regulatory required actions, we expect the overall mission to be impacted by frequent "system shutdowns".  Also, the ability to conduct the proposed frequent testing will be severely limited by installation staff responsible for maintenance and operations and their availability.  In addition, for those installations that are government owned and contractor operated, numerous contract modifications will be required to support this new requirement.  
Further, due to release detection technology requirements, we expect significant infrastructure modifications and changes will be required to enable test method application.  Some of these actions may require Military Construction (MILCON) funding, projects that require Congressional approval with five year advance planning, which could significantly delay the Department of Defense's (DoD's) ability to be compliant.  
As you can see, your proposed path forward will have a cascading negative impact.  However, we are in agreement that we jointly should continue to seek solutions that will support the protection of the environment, take into consideration the funding process and requirements, while allowing the critical mission to proceed.  As you know, we "walk the walk" on this as evident by our current Leak Detection Program best management plan to perform release detection even when not required by regulation.
The following are specific comments and recommendations on the draft deliberative documents provided.
COMMENTS ON DRAFT DELIBERATIVE DOCUMENT  -  AIRPORT HYDRANT FUEL DISTRIBUTION SYSTEMS
Introduction Comments
With regards to the applicability to piping using diameter (you propose in your draft deliberative document that > to 6 inches, new requirements apply; <6 inches, current piping requirements apply), it is not possible to separate out and conduct different testing by diameter.  Military airport hydrant systems are very complex with various diameters ranging from 4 to 20 inches.  Piping with different diameters may not be able to be isolated and tested separately.  We strongly recommend that any new requirements be developed for and apply to what ultimately is the definition of an airport hydrant system, irrespective of diameter.  Thus, we disagree with your proposed approach to apply current release detection requirements to hydrant piping <6 inches in diameter.
1.  Line Leak Detector:  With regards to line leak detector requirements for Airport Hydrant Fuel Distribution Systems, we believe any regulation put forward should be based on the current availability of technologies able to meet the regulation, not on driving research and development.  As technology becomes available, regulations could be updated accordingly.
2.  RD Methods/Precision Test Annually to 1.0 gallon per hour (gph):  The sensitivity and frequency requirement in this section should be greater than proposed in 4.
3.  Not sure this section is relevant or would apply to military hydrant systems.
4.  Performing Testing:  Taking into consideration the environment, funding and mission we propose for your consideration a reduction in the proposed quarterly frequency to annual and increase in the minimum detectable leak rate from <1.5 gph to <3 gph.  We believe most of the testing we have performed would be able to meet this requirement.  We recommend this be the only option.  To add another test at a lower sensitivity to any section where the MDLR is >3gph is not reasonable.  In these cases we would be forced either use the more costly test method with a lower sensitivity or perform infrastructure changes.
We continue to evaluate the leak rate versus volume table you provide, but were unable to complete before submission of this document.

COMMENTS ON DRAFT DELIBERATIVE DOCUMENT  -  FIELD CONSTRUCTED USTS
We recommend options be added to accommodate monthly monitoring via ATG capable of achieving the following leak rate ranges, coupled with the related precision test frequency and leak rate:
   * 0.3 gph  -  1 gph ATG MDLR coupled with a precision test every three years to 0.1 gph;
   * 1.0 gph  -  2.0 gph ATG MDLR coupled with a precision test every other year to 0.1 gph
We concur with your proposed option to conduct annual precision test to 0.5 gph MDLR for USTs >50,000 gallons.  However, there are a couple military locations unable to meet any of the options above.  We need to discuss how to reasonably cover these facilities.
Regarding piping associated with these USTs, it is important to define the Field Constructed UST to include reasonable lengths of piping going from the UST up to the first isolation point as part of the UST.  Also, underground pressurized piping originating from ASTs, piers, or defined as interstate/intrastate transfer piping should be excluded.


COMMENTS ON DRAFT DELIBERATIVE DOCUMENT  -  Scenarios 1-5
For scenarios 2, 3 and 5, it is important to state the definition of AST system to include AST and piping up to the UST (as long as the piping is less than 10% volume).  We recall you stating that the leak detection applicability for the piping from the AST to the field constructed or traditional UST was "still under discussion".   NOTE: any piping that is >10% of volume of the AST(s) should be required to meet the release detection requirements as recommended above.

QUESTIONS/CLARIFICATIONS
Below, I would like to provide answers to other questions resulting from the meeting, as well as points of clarification.
Definitions for Airport Hydrant and Field Constructed USTs (and associated piping)
Due to the complexity and lack of similarity of our systems, it is difficult to provide a comprehensive definition.  It may be best to simplify by illustrations similar to those provided in scenarios 1-5.
Separately, we recommend EPA provide clarification on how to reconcile potential dual regulation of field constructed USTs that are functioning as break out tanks.

Table of typical field constructed UST size, duration of test and leak rates
After review of select installations with field constructed USTs, we believe that most of the DoD owned USTs would be able to be compliant with the above options for leak detection.  Typically, DoD field constructed UST s capacity range from 50,000 gallons to 2.2 million gallons.  One installation has USTs with capacities that exceed 12 million gallons.  Below is summary data for examples of select field constructed USTs and tests that have been performed. (Please note that although the MDLR represented below is achievable, it is very rare that we would be able to remove tanks from mission service for the length of time required, particularly for the 135' and 122' diameter tanks.)
                                   Capacity
                                   Diameter
                                   Test Time
                                     MDLR
                                 2.2M Gallons
                                    135'
                                   288 Hours
                                    0.1 gph
                                 2.1M Gallons
                                    122'
                                   192 Hours
                                    0.1 gph
                                 1.2M Gallons
                                    99.5'
                                   96 Hours
                                    0.1 gph
                                    579,000
                                     88'
                                   72 hours
                                    0.1 gph
		
Diameter, length, volume and number of sections of hydrant piping
We estimate that piping diameter ranges from 4" to 20".  Piping lengths range from <50' to >30,000 feet.  Volume ranges from <3,000 gallons to > 300,000 gallons.  Number of test sections per facility range from 1 to >13.

Examples of fuel system layouts
Unfortunately, due to security reasons, we are unable to provide as is detailed drawings of our current systems.  We are working on generic typical system layouts, but will be unable to meet your deadline.  We will provide these as soon as possible.

Double-walled construction requirements for all new UST and pressurized piping facilities
During the meeting you referenced the above and the recent Energy Act.  Can you provide clarification to this requirement and its applicability to Field Constructed USTs and Airport Hydrant Systems?  As stated during our last meeting, double walled piping brings significant engineering challenges with providing adequate cathodic protection and release detection.  As a result, the DoD standard design for underground piping is single-wall with cathodic protection and a maintenance schedule that includes an annual pressure test.  In our experience properly maintained and protected single-walled piping is more protective of the environment than double walled piping due to the unreliable means of providing cathodic protection and release detection. 
