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HomeMy WebLinkAboutBOA Add'l Items 2-26-2015 Letter from Webb EngineeringWEB ENGINEERINCI ASSOCIA'FES, fNC, 104 LONGIAIXIIIR DRIVE�* NIORWE'Ll, NIASSACHUSE"I"T'S 02061 781-878-7766 - FAX: 781-878-8004 1-800-273-7289 Januaty 20, 2015 .Mr. David Dickey Planning & Zoning Director City of Cape Canaveral 110 Polk Avenue P.O. Box 326 Cape Canaveral, FL 32920 Ref, Proposed New Petroleum Storage, Fuel Dispensing and Environmental Protection at the Proposed Cumberland Farms Convenience Store, 6455 North Atlantic .Avenue Dear Mr. Dickey, The following is a Third Party Evaluation of the Fuel Guidelines for Proposed New Petroleum Storage, Fuel Dispensing and Environmental Protection for Cumberland Farms, Inc. (CFI). This third party evaluation is based on the following CFI underground storage tank (UST) plans dated January 8, 2015 and Atkins Site Plan dates August 8, 2014: • Sheet No. CFG04.0: Site Plan • Drawing No. CFG14,0: UST Cover Sheet • Drawing No. CFO 14.1 Material List • Drawing No. CFGI 4.2 Tank Installation Details • Drawing No. CFGI.4.3 Tank Installation Details • Drawing No. CFG14.4 Sump & Piping Details • Drawing No. CFG'I 4. 5 Tank Installation Details • Drawing No. CFG14,61'ank Installation Details CFI proposes to install a vehicle fueling station at 6455 North Atlantic Avenue, Cape Canaveral, Florida. The proposed station will consist of two 20,000 gallons USTs supplying gasoline and diesel fuel to seven fuel dispensers capable of fueling 14 vehicles simultaneously. The fueling station will be "state of the art" for petroleum storage, meeting or exceeding state and fWeral regulations for underground petroleum storage. This report is divided into four sections. They are: 1, Environmental Protection 1 Operations 3, Release Detection 4, Conclusion. Petroleum. Chemical Operalions Engineering .. [mmk Management - Ronwhation S)-vol"s - 1-tw-ardalls, Solid I-flave S'I%Ytons -Site Investigations - Regulato)y Compliance I. ENVIRONMENTAL PROTECTION: In addition to meeting state and federal regulations, the fueling station will meet the standards associated with the following organizations: • API American Petroleum Institute • ASML American Society of Mechanical Engineers • ASTM American Society for Testing and Materials • AWWA American Water Works Association • FM Factory Mutual Research • NSF National Sanitation Foundation • UL Underwriters Laboratories, Inc. The tanks and the piping will be installed by qualified contractors. T'he contractors must be certified by the tank and the piping manufacturers. The Petroleum Equipment Institute and the American Petroleum Institute, as well as the manufacturers, provide reconnnended practices for the installation of tanks and. piping. A. Tanks: The proposed tank schedule consists of two 20,000 gallon USTs. Each tank will have two compartments. In the first tank, each compartment will contain 12,000 gallons of regular gasoline and 8,000 gallons of premium gasoline. In the second tank, each compartment will contain 12,000 gallons of regular gasoline and 8,000 gallons of diesel fuel. The UST's will. be double walled, fiberglass reinforced plastic (FRP) construction. FRP is manufactured by embedding glass fiber reinforcement in a cured thermosetting plastic. Thermosetting plastics are resins that undergo an irreversible reaction when cured in the presence of a catalyst. Cured thermosetting resins cannot be re -melted and are insoluble to gasoline and diesel fuels, as well as soil environments. The space between the inner and outer walls, known as the interstice, is filled with a brine solution. Brine is a calcium chloride solution that is resistant to freezing and does not adversely affect FRP. The brine level is monitored using a liquid. level sensor. Should the inner or outer wall of the double walled tank fail, the sensor will detect a change in the brine level. The liquid level sensor will then activate an audible/visual alarm that can be heard by CFI personnel. It should be noted that the USTs are additionally monitored by a water sensing device (the Veeder Root Inventory Probe), which would detect brine in the tank, should the inner wall fail. In March of 2006, William E. Baird, PE of Web Engineering Associates, Inc. (WEIR), contacted Mr. Sully Curran of the Fiberglass Tank Institute regarding releases from double wall FRP tanks. h1 that conversation, Mr. Curran stated, "it is safe to say that there are 100,000+ double wall tanks in service.. -There have been no releases to the environment from double wall tanks anywhere since first required by California some 20 years ago... including earthquakes". Mr. Curran was contacted again in 2014. His reply was the same, adding "only double the number of tanks to 200,000--." h1 a report prepared by the University of California, Davis dated March 2001 submitted to the USIPA entitled, Field Verification of the Performance gf'Release Detection Methods fbr N Underground Storage Tank Systems, it was reported that there were no releases to the environment from double wall FRP tanks with interstitial monitoring (although the population of tanks in the study was small as it represented tanks removed from sites that were being closed). In a second report by Dr. Thomas M. Young, MD., Department of Civil & Environmental Engineering, University of California, Davis dated May 31, 2002, entitled Underground Storage Tank System Field -Based Research Project Report, it was concluded that there were no liquid releases from 137 double walled, FRP tanks in the population of tanks tested. While the population of tanks in the above University of California, Davis studies was small, the studies seem to confirm the results reported by Mr. Curran. B. Piping/UST Sump Containment All piping associated with the fueling station will be double walled, FRP construction. The inner "pressurized" pipe contains the gasoline or diesel fuel. The outer pipe provides containment to the inner pipe and protects the inner pipe from the surrounding soils. In the event of a failure in the inner pipe, the outer pipe, which is pitched toward the tank, would direct the fugitive product to a UST containment sump. Each UST containment sump has a liquid sensor located at the bottom of the sump. The liquid sensor, which detects the liquid, creates an audible/visual alarm and deactivates the fuel pump. The UST containment sump has a volume of approximately 180 gallons. In regard to the above University of California, Davis study, Dr. Young reported one piping leak in all of the systems he examined. However, the leak was from a "single wall pressurized piping component", not a double -walled piping system. In addition to the liquid level sensor, all pressurized piping is equipped with a Veeder-Root Pressurized Line Leak Detector (PLLD). Should a leak occur in the pressurized piping, the PLLD activates an audio/visual alarm and terminates the transfer of product through the piping. C. Dispenser Sump Containment All dispenser sumps are situated over containment sumps. These sumps also have liquid sensors. Should a dispenser leak develop, the containment sump would contain the fugitive liquid. The liquid sensor would detect the fugitive liquid and activate an alarm. The dispenser containment sump would hold approximately 100 gallons of product. In addition to dispenser leaks, the dispenser sump would contain underground piping leaks that occur in the vicinity of the dispenser. Thus, there is a redundant system to detect primary piping leaks. D. Tank Filling/Fill Containment Buckets The USTs are filled via liquid tight hose connections located at the tank tops. Each hose connection is located inside a five -gallon fill containment bucket. The fill containment bucket is designed to catch any drips that may occur while the truck operator is disconnecting his hose. The fill containment bucket is double walled. The double walled fill containment bucket has an integrity test port for testing the space between the inner and outer walls. F. Overfill Protection The liquid level in the UST is monitored using the Veeder root Inventory Monitoring system referenced above. The liquid level probe consists of a float that rises and falls with the liquid level in the UST. The inventory monitoring probe activates an audible/visual alarm when the level of product in the UST reaches 90%. Fuel enters to the tank during filling through an. aluminum drop tube. The drop tube terminates at the bottom of the tank to minimize splashing. The aluminum fill tube is equipped with a float valve. The float valve stops the flow of product into the tank when the level of product in the tank reaches 95% of the capacity of the tank. F. Vapor Recovery Also located on top of the tank is a vapor return pipe. The truck operator connects a hose to the vapor return piping. In this manner, vapors from the UST are directed to the vapor space of the delivery truck, instead of into the environment. The vapor return pipe also is equipped with a 5 gallon spill containment bucket. The spill containment bucket will collect any condensate that may occur in the vapor return hose. The gasoline delivery and tank venting system will meet California Air Review Board (CARR) certification requirements. G. Tank Installation Because the USTs are typically submerged in groundwater, measures are taken during installation to prevent floatation of the UST. To accomplish this, the tanks are anchored to concrete ballast structures placed below the tanks using straps supplied by the tank manufacturer. The straps are placed over the tops of the tanks and anchor the tanks to the concrete structure. In the event of a high water table, the anchoring prevents empty tanks frorn floating. The tanks and piping are bedded in clean, sized, crushed stone. The stone protects the tanks and piping from rocks that may be in the native soil. The excavation is lined with a geotextile fabric. The geotextile fabric prevents native soils from migrating into the stone bedding. Inside the tank excavation are "observation wells." The wells extend below the bottom of the tanks. The observation. wells provide a convenient nlethod to determine if product has been released to the environment. 4 H. Dispenser Protection Underground piping transitions to aboveground piping at the base of the dispenser (inside the dispenser containment sump). The transition is made using a double -poppet, emergency shutoff valve. This valve performs two services. In the event of a traffic accident involving a dispenser, this valve is designed to shear at a predetermined section of the valve. When the valve shears, the poppets close, sealing off the piping to and from the dispenser. Secondly, the poppet is held open by fusible linkage. In. the event of a fire, the linkage melts and the poppets close. Nuel is then prevented from feeding the tire. The hose on the dispenser contains a breakaway coupling (dry -break connection). Should a driver drive off with the hose nozzle still in the vehicle fill pipe, the dry -break will sever. Mechanisms inside the dry -break prevent the release of little more than a few drops of product from either the dispenser -side or the nozzle -side of the hose. The nozzle that is placed in the vehicle fill pipe has a self-closing shutoff valve. The valve closes automatically as product fills the fill tube. Should the automatic valve fail, the operator would release the lever on the valve and much less than a gallon of product would be released. (The vehicle tank fills with product at less than 10 gallons per minute. I:f it takes two seconds for an operator to react, the amount released will be about 1/3 of a gallon. When a vehicle is fueling, it is positioned on a concrete drive mat. The mat contains a series of V shaped "grooves" scribed around the perimeter of the concrete drive mat. The grooves are called Positive Limiting Barriers (PLBs). In the event of a spill, the PLBs prevent the fugitive liquid from flowing freely off the drive mat. These PLBs typically contain 10 to 15 gallon spills. It should be noted that the length of the fuel hose restricts the filling of'vehicles beyond the limits of the PLBs. II. OPERATIONS: A. Fuel Delivery Fuels are delivered in transport trucks. Before fuel is scheduled to be delivered to a location, the CFI dispatcher knows the volume in the underground storage tanks. This is done electronically though the ATG system. This procedure ensures that the tanks will not be overfilled. When the truck enters the site to make a delivery, the driver is required to manually determine that the tanks will hold the product. The driver opens the cover of the spill containment sump and removes the cap on the fill pipe. The driver inserts a calibrated. wooden stick (pole or rod) into the tank, withdraws the stick and reads the elevation of the product in the tank. He then checks the elevation of the product against a calibrated tank chart. The chart indicates the amount of product in the tank. The driver then knows if the tank will hold the product that is in the truck. "Sticking the tank" is a check against the Automatic Tank Gauge and the Dispatcher. Once the driver has determined the tank will hold the product, the driver removes two hoses f otn a shelf on the truck and connects one hose to the tank frill pipe and to the product manifold on the truck. The second hose is for vapor recovery. This hose attaches to the Stage One Vapor Recovery Piping. When the hoses are safely connected to the tank piping and the tanker truck piping, the safety valves on the truck are opened and product flows from the truck to the tank. As product begins to flow, the driver checks for leaks. If a leak occurs, the driver shuts the valves on the truck manifold and makes a repair. Any gasoline that has dripped on any surface is carefully removed with absorbent pads. The driver is required to remain by the truck manifold as long as the hoses are connected to the truck and the underground storage tank. Absorbent pads contaminated with gasoline of diesel. fuel are safely stored on site and removed in accordance with Florida regulations. Generally, product flows through the hose at less than 500 gallons per minute. Should a hose fail, it will take the driver less than 4 seconds to close the tank truck valves. The release will be less than 40 gallons. Should a tanker truck hose failure occur, the Fire Department is notified immediately and the CFI dispatcher is notified. A Hazmat company is called to remove the spill from any containment structure. When the truck tank is empty, the driver closes the valve at the truck manifold and disconnects the hose from the truck manifold. The hose is "rolled" toward the tank such that any product in the hose drains into the tank. When the driver is certain there is no product in the hose, he disconnects and the hose ftoln the tank and places caps on the hose and the tank f`iII pipe. Any product dripping from the hose during this operation is captured in the 5 gallon spill containment sump. CFI uses only CFI drivers and trucks to deliver fuel. The drivers are well trained and DOT certi-fi ed. B. Operator Certification The federal government requires the training and certification of underground tank operators that involve regulated substances. 'There are three categories of operators for each underground tank: A, B, C. The A operator is responsible to be certain that regulations are being met at the company level. The B operator must know the equipment and operation of the tank system and on a monthly basis inspect the tank systems. This includes monthly inventory control in accordance with current regulations. A & B operators are required to take and pass a test. The test is administered by computer "on line" at an American Petroleum Institute website. The A and or B operator is also responsible for training C operators. C operators must be present whenever a tank system is in operation. The C operator must be trained to respond to emergencies. Currently, A, B, and C operator requirements are Federal in Florida. Florida Regulations, F.A.C., require all UST owners to have designated and trained operators by August 6, 2015. As of August 7, 2014, the training program must meet the Florida requirements specified in Rule 6 62-761.350, F.A.C. Training Certificates from other states will no longer meet Florida's requirement. Certificates issued from other states will not be accepted in Florida after August 6, 2015, Every CFI facility that dispenses motor fuels meets Federal requirements. III. CONCLUSION: Based on the plans referenced at the beginning of this letter, the proposed CFI Gasoline Station meets all requirements for the safe storage and dispensing of fuels. We trust that this letter demonstrates the above conclusion. If you have any questions, please call. Very truly yours, Web Engine mg Associates, Inc. Robert P. Coluccio, PE Florida PE No. 58338