31366 805 HOLLOMAN 1166 CMP NOV FOC 34 20220910 0027.pdf
PDF 4 MB Posted
- Attached to
- Fuel Tank Repairs Holloman AFB
- Solicitation number
- FA480123Q0435
View the file
Other files
On GovTribe
Work with this file
- Download the original file
- Contacts named in this file
- Similar government files
- Ask GovTribe AI about this file
Text version
New Mexico Environment Department Petroleum Storage Tank Bureau 2905 Rodeo Park Drive East, Bldg. 1 Santa Fe, NM 87505
(505) 476-4397
34 20220810 0027
This facility was cited with Class B violation(s) pursuant to section 20.5.116.1602.B(1) of the Petroleum Storage Tank Regulations, Title 20 Chapter 5 of the New Mexico Administrative Code ("NMAC"). The Class B violation(s) cited below indicate that the PSTB has identified violation(s) at this facility that qualify certain tanks for ineligibility to receive product (fuel). If not corrected within 30 days of the date of this notice, a Notice of Deficiency will be issued pursuant to 20.5.116.1602.B(2) NMAC, and may eventually lead to red tag placement and ineligibility for delivery of the system under violation pursuant to 20.5.116.1602.C NMAC.
If the violation(s) cited are not corrected, the facility may be determined to be out of compliance with the requirements and provisions of the Petroleum Storage Tank Regulations which would mean the facility would not be eligible for reimbursement from the Corrective Action Fund (see 20.5.123.2304 NMAC) if the facility has a release.
II. Violation(s) Information.
Tank ID Penalty Code
Occurrences Per Tank Description
36248 20.5.110.1005.
D [2]
Failure to meet overfill prevention requirements no later than July 24, 2021 and every three years thereafter.
36248 20.5.109.910.E
[1] 1 Failure to meet requirements for spill prevention on ASTs previously exempt from spill prevention requirements.
III. Signature.
Compliance Officer Print Name: Claudia K. Guillen
Compliance Officer's Signature:
Date: November 21, 2022
Notice of Violation Class B Violations Subject to Delivery Prohibition
Date: November 21, 2022
I. Facility, Ownership, and Operator Information Facility Name: US AIR FORCE BLDG 1166 Facility Number: 31336
Facility Address: BLDG 1166 HOLLOMAN AIR FORCE BASE, NM 88330
Operator Name: US AIR FORCE - HOLLOMAN AFB Operator Number: O882
Owner Name: US AIR FORCE - HOLLOMAN AFB Owner Number: 805
New Mexico Environment Department Petroleum Storage Tank Bureau 2905 Rodeo Park Drive East, Bldg. 1 Santa Fe, NM 87505
(505) 476-4397
34 20220810 0027
Date: November 21, 2022
I. Facility, Ownership, and Operator Information Facility Name: US AIR FORCE BLDG 1166 Facility Number: 31336
Facility Address: BLDG 1166 HOLLOMAN AIR FORCE BASE NM 88330
Owner Name: US AIR FORCE - HOLLOMAN AFB Owner Number: 805
Operator Name: US AIR FORCE - HOLLOMAN AFB Operator Number: O882
This facility has been cited with Class C violation(s) of the Petroleum Storage Tank Regulations, Title 20 Chapter 5 of the New Mexico Administrative Code ("NMAC"). If the violation(s) cited are not corrected, the facility may be determined to be out of compliance with the requirements and provision of the Petroleum Storage Tank Regulations which would mean the facility would not be eligible for reimbursement from the Corrective Action Fund (pursuant to 20.5.123.2304) if your facility has a release.*
Field Compliance Order
II. Violation(s) Information.
Tank ID Penalty Code
Occurrences Per Tank Description
36248 20.5.102.207.A 1 Failure to display a current and valid registration certificate at the facility.
36248 20.5.110.1001.
A (1)
Failure to include required information and documentation in Operations and Maintenance Plan.
36248 20.5.111.1100.
A 1 Failure to conduct monthly visual inspection of above ground storage tank.
36248 20.5.104.409.B[1 ] 1 Failure to have Class A/B Operator perform monthly inspections.
36248 20.5.110.1008.A 1 Failure to conduct periodic walk-through inspections.
Compliance Officer Print Name: Claudia K. Guillen
Compliance Officer's Signature:
Date: 11/21/2022
* Tank owners and operators are required to comply with all applicable regulations and with the Governor's current Executive Orders and Public Health Orders. If tank owners and operators are unable to comply with the regulations or need to delay activities as a result of the COVID-19 pandemic including related travel and social distancing restrictions imposed by both governments and corporations, entities should use existing procedures to request extensions or notify the Bureau in writing as soon as possible. The Bureau will evaluate each ongoing violations in consideration of continued work to protect human health and the environment. For the most up-to-date COVID-19 information including COVID Safe Practices please visit the New Mexico Department of Health website, cv.nmhealth.org.
Aboveground Storage Tank Systems Inspection Report
Fax: 505.476.4374 Phone: 505.476.4397 Santa Fe, NM 87505 2905 Rodeo Park Drive East, Bldg. 1 Petroleum Storage Tank Bureau
Date: 10-Aug-21Inspection Start Time: 11:30 AM Case Number: 34 20220810 0027Inspection Type: Compliance
E-mail: scott.dorton@us.af.milContact Name: Scott Dorton
Zip Code: 88330State: NMCity: HOLLOMAN AFBAddress:49 CES/CEV 550 TABOSA AVE
Phone: 505-572-3931Owner ID: 805II. Owner Name: US AIR FORCE - HOLLOMAN AFB
E-mail: scott.dorton@us.af.milContact Name: Scott Dorton
Zip Code: 88330State: NMCity: HOLLOMAN AFBAddress: 49 CES/CEV 550 TABOSA AVE
Phone: 505-572-3931Operator ID: O882III. Operator Name: US AIR FORCE - HOLLOMAN AFB
Zip Code: 88201State: NMCity: Roswell Address: 1914 W 2nd St
E-mail:claudiak.guillen@env.nm.govPhone: 575-361-0216V. NMED Compliance Officer's Name: Claudia K. Guillen
VI. Tank Number 36248
Size/Capacity: 2000
Contents: B02
Installation Date: 08/09/2001
Tank Construction: A01/06
Tank Secondary Containment: S16
Piping Construction: F01/91
Piping Secondary Containment: S17
Other Secondary Containment / Ancillary:
Corrosion/Cathodic Protection: C19/20
Tank Release Detection: H07
Piping Release Detection: G16
Spill Prevention: I03
Overfill Prevention:
Tank Status & Usage: IN USE
LUST Site:Access to property authorized by: Jessica Gutierrez E-mail:jessica.gutierrez.11@us.af.mil
Zip Code: 88330City: HOLLOMAN AIRFORCEAddress: BLDG 1166
Phone:Facility ID: 31336I. Facility Name: US AIR FORCE BLDG 1166
Date Trained: 03/22/2022Who trained Class A/B Operator: anteagroup
Zip Code:State:City:Address:
E-mail:Phone:IV. Class A/B Operator Name: Philip Collado #115689747
New Mexico Petroleum Storage Tank Bureau Aboveground Storage Tank Systems Inspection Checklist
Case Number: 34 20220810 0027Facility ID Number: 31336 of 6Page 2
1. Registration (20.5.102 NMAC) and Tank Fees (20.5.103 NMAC) N/A
A. Are all applicable tanks registered? (20.5.102.200 NMAC) Yes
B. Current & Valid Registration Certificate on-site? (20.5.102.207 NMAC) No
C. Owner Mailing address is correct? (20.5.102.208 NMAC) Yes
D. Owner in compliance with tank fees. (20.5.103.300 NMAC) No
E. Notification of transfer of ownership submitted per (20.5.102.201 NMAC) N/A
2. Operator Training (20.5.104 NMAC) N/A
A. Class A&B Operator(s) designated for the storage tank system(s). (20.5.104.400 NMAC) No
B. Class A&B Operator(s) conducting monthly inspections. (20.5.104.409.B NMAC) No
C. Class A&B Operator(s) must retrain within the next 60 days due to significant violation(s). (20.5.104.406.B NMAC) N/A
D. Class A/B Operator retrains: Every 5 Years
E. Class A/B Operator retrained by NMED Inspector following significant violation. N/A
F. Operator Training requirements have been met for Class A/B and C. (20.5.104 NMAC) N/A
3. Operations and Maintenance Plan (20.5.110.1001 NMAC) N/A
A. Operations & Maintenance Plan at the facility? No
B. Operations & Maintenance Plan updated? No
4. Financial Responsibility (20.5.117 NMAC) N/A✔
5. Release Prevention N/ARecords Review
A. Spill Prevention Equipment: Remote Fill Box
Tank(s) in Violation
1. Equipment is present? (20.5.109.910.A NMAC) Yes
2. Equipment is free of tears, rips, or damage. (20.5.110.1005.C NMAC) Yes
3. Equipment has adequate volume to contain spills. (20.5.110.1005.C NMAC) Yes
4. Equipment free of regulated substance, debris, water, or other liquids. (20.5.110.1005.C) Yes
5. Equipment free of minor damage or other operational defects. (20.5.110.1005.C NMAC) Yes
6. Equipment tested within the last 3 years & report submitted within time frames? (110.1005.C) No 36248
7. Equipment passed the test? (20.5.110.1005.C(4) NMAC) N/A
8. Test conducted per regulations and by tester who meets qualifications. (110.1005.G) N/A
9. Integral spill bucket monitored monthly or tested every 3 years. (20.5.110.1005.C(3) NMAC) N/A
10. Equipment is listed per national standard or code of practice. (20.5.109.910.F NMAC) Yes
11. Drain valve on remote fill box is closed? (20.5.110.1005.C NMAC) Yes
B. Overfill Prevention Equipment: Overfill Alarm
Tank(s) in Violation
1. Equipment is present? (20.5.109.910.A(2) NMAC) Yes
2. Equipment is operational/functional? (20.5.110.1005.D NMAC) No 37646
Case Number: 34 20220810 0027Facility ID Number: 31336 of 6Page 3
3. Alarm audible and visible to delivery driver? (20.5.109.910.A(2)(b) NMAC) Yes
4. Equipment inspected or tested per regulations within last 3 years? (20.5.1010.1005.D NMAC) No 36248
5. Equipment passed periodic inspection or test? (20.5.110.1005.D NMAC) No 36248
6. Inspection/Test report submitted within required time frames. (20.5.110.1005.D(5) NMAC) No 36248
7. Inspection/Test conducted per regulations and by tester who meets qualifications. (110.1005.G) No 36248
8. Equipment is listed per national standard or code of practice. (20.5.109.910.F NMAC) N/A
C. Corrosion Protection N/A
1. Tank(s): None
Tank(s) in Violation
a. Steel Tank system protected from corrosion. (20.5.109.902.A NMAC) Yes
b. Corrosion protection is operational. (20.5.110.1006.A/115.1501.A(1) NMAC) N/A
c. Impressed Current System monitored every 60 days. (20.5.110.1006.C/115.1501.A(1) NMAC) N/A
d. Cathodic Protection system tested every 3 years/within 6 months of repair. (1006.B/115.1501.A) N/A
2. Piping: None
Tank(s) in Violation
a. Steel piping / flex connector(s) protected from corrosion. (20.5.109.913.A NMAC) Yes
b. Corrosion protection is operational. (20.5.110.1006.A NMAC) N/A
c. Corrosion protection is inspected monthly. (20.5.110.1006.D NMAC) N/A
d. Containment sump(s) free of water and soil. (20.5.110.1007.A NMAC) N/A
3. Cathodic Protection Test. Tank(s) in Violation
a. Report contains all required information. (20.5.110.1006.B NMAC)
b. Report contains test data for all steel tanks and steel piping at the facility. (20.5.110.1006.A)
c. Cathodic protection system passed the last test. (20.5.110.1006.A NMAC)
d. Test conducted by tester who meets qualifications. (20.5.105.504 NMAC)
6. Release Detection N/A
A. Tank(s): Visual Inspection
Tank(s) in Violation
1. Applicable method is present. (20.5.111.1100.A/112.1205/1206 NMAC) No 36248
2. Tank(s) being monitored monthly for releases. (20.5.111.1102 thru 1104 & 115.1501.A NMAC) No 36248
3. Method is being operated and maintained as required. (20.5.111.1102 thru 1104 NMAC) No 36248
4. Equipment inspected or tested annually for operability and serviceability.(1102 thru 1104) N/A
5. Annual inspections and testing conducted by tester who meets qualifications. (111.1100.D) N/A
6. Records are being maintained. (20.5.111.1111 NMAC) No 36248
7. Integrity Test performed prior to return-to-service. (20.5.115.1501.I NMAC) N/A
B. Piping: Visual Inspection
Tank(s) in Violation
Case Number: 34 20220810 0027Facility ID Number: 31336 of 6Page 4
1. Applicable method is present. (20.5.111.1105 thru 1109 & 112.1205/1206 NMAC) Yes
2. Piping being monitored monthly for releases. (20.5.111.1100.A NMAC) No 36248
3. Method is being operated and maintained as required. (20.5.111.1105 thru 1109 NMAC) No 36248
4. ALLD is capable of detecting leaks. (20.5.111.1105.A(1)) NMAC) N/A
5. ALLD Functionality tested within last 12 months (20.5.111.1105.A(2)/1106.A(2) NMAC) N/A
6. Requirements have been met for no ALLD on aboveground piping (20.5.111.1109.B NMAC) N/A
7. Tightness test conducted within required time frames. (20.5.111.1105.A/1107.A(1) NMAC) N/A
8. Records are being maintained. (20.5.111.1111 NMAC) No 36248
9. Interstitial monitoring has automatic shutoff and sensors tested annually. (1106.A(3)/1108.A) N/A
10. Interstitial monitoring for emergency generator triggers alarm & tested annually. (20.5.112) N/A
11. Equipment inspected or tested by tester who meets qualifications. (20.5.105.504 NMAC) N/A
7. Containment N/ARecords Review
Tank(s) in Violation
A. Secondary containment installed on new or upgraded AST system. (20.5.109.900/908 NMAC) Yes
B. Under-dispenser containment is present? (20.5.109.917 NMAC) N/A
C. Transition sump is present for above-ground piping? (20.5.109.913.D NMAC) N/A
D. Containment for loading rack is present and meets volume requirements? (20.5.109.918 NMAC) N/A
E. Containment is operated and maintained as required? (20.5.110.1002/1003/1007/1008 NMAC) Yes
F. Periodic testing conducted on sumps used for interstitial monitoring.(20.5.110.1007 NMAC) N/A
G. Double walled containment sumps used for interstitial monitoring is monitored every 30 days. N/A
H. Periodic testing of sumps reported within required time frames.(20.5.110.1016 NMAC) N/A
I. Sump testing conducted per regulations and by tester who meets qualifications. (105.504) N/A
8. Periodic Walk-through Inspections (20.5.110.1008 NMAC) N/A
Tank(s) in Violation
A. Inspections conducted every 30 days. (20.5.110.1008 NMAC) No 36248
B. Spill and overfill prevention is inspected every 30 days. (20.5.110.1008.A(1) NMAC) No 36248
C. Containment sumps inspected every 30 days. (20.5.110.1008.A(3) NMAC) N/A
D. Release detection equipment checked every 30 days for alarms, signs of release. (1008.A(2)) N/A
E. Equipment/material used to isolate metal components inspected every 30 days. (110.1006.D) N/A
F. Records maintained. (20.5.110.1008.D NMAC) No 36248
9. Tank(s)/Piping/Operations & Maintenance N/A
Tank(s) in Violation
A. Ancillary equipment is maintained. (20.5.110.1000 NMAC) No 36248
B. Fill port lids are marked. (20.5.110.1000(A) NMAC) Yes
C. Normal venting is maintained. (20.5.110.1004 NMAC) Yes
D. Emergency vents are maintained and inspected monthly.20.5.110.1004 NMAC) No 36248
E. Underground piping replaced that shows signs of deterioration/failure. (20.5.110.1010.A) N/A
Case Number: 34 20220810 0027Facility ID Number: 31336 of 6Page 5
F. Sump liners and penetration boots are maintained as required.(20.5.110.1007 NMAC) N/A
G. AST system is documented to be compatible with contents greater than E10 or B20. (1009.B) Yes
H. AST is compatible with the regulated substance stored? (20.5.109.1009 NMAC) Yes
10. Notifications and Records N/A✔
11. Evidence of a release or spill: No
12. Attachments Pictures✔ Site Sketch✔ Records✔ Re-training module Other✔ Financial Respons.
13. Comments.
A. Tank Certificate: A tank certificate was not posted or provided for this fuel system as required in 20.5.103.300 NMAC. Violation 207.A, Level C. (TID# 36248), 1 occurrence per tank. Failure to display a current and valid registration certificate at the facility. Solution: provide NMED inspector proof that a current and valid registration certificate is post at the facility within 30 days of receipt of this report.
B. Spill Containment: Owner was previously exempt from spill prevention, as spill prevention fill ports are located within the Loading area concrete secondary containment system. Owner is required to meet new spill prevention requirements no later than July 24, 2021, and every three years thereafter as required in 20.5.109.910.E NMAC. Violation 910.E, Level B, (TID# 36248), 1 occurrence per tank. Solution: Owner shall install spill prevention equipment within 30 days from this report.
C. Overfill protection: Morrison Bro. clock gauge. Overfill clock gauge alarm, overfill is not functioning. Owner/operator of AST didn't provide 3-year test report, Violation 1005.D[2], Level B. (TID# 36248) (I occurrence per tank), Failure to meet overfill prevention requirements no later than July 24, 2021, and every three years thereafter. Solution: Have the overfill devices tested by certified tester and submit test results to Bureau 30-days after receipt of this report.
D. Vent Line Risers & Emergency vents; No visible damage was noted at the time of inspection. Tank system is equipped with atmospheric venting.
E. Piping: No visible damage was noted at the time of inspection.
F. Tanks: No visible damage to the tanks was noted at the time of inspection.
G. Tank/Piping Release Detection: Owner has not meet requirements for periodic walk-through inspections as required in 20.5.107.707 NMAC. Violation 1100.A, Level C. (TID# 36248), 1 occurrence per tank. Solution: Owner must have an A/B operator conduct the walk-through inspections every 30-days, not to exceed 30 days and maintain those records for the life of the tank system in accordance with
20.5.107.707.A NMAC.
H. Operation & Maintenance Plan (OMP): Owner/ operator submitted an outdated OMP, not current with the new rules. Violation 1001.A(l), Level C. (TID# 36248), 1 occurrence per tank. Failure to include required information and documentation in Operations and Maintenance Plan. Solution: At a minimum, the operations and maintenance plan shall include the following:
1) Include the inspections and testing requirements for spill & overfill prevention equipment, release detection equipment, and containment sumps used for interstitial monitoring of underground piping.
2) Include a tank chart for each UST at the facility.
3) Describe how soil and water that are removed from the tank system will be disposed of if it might be or is contaminated.
4) Include the applicable 30-day periodic walk-through inspections in 20.5.107.707 NMAC (20.5.111.1102 and 20.5.110.1008 NMAC) for the facility.
5)Site Map
I. A/B & C Operator Training: The site does not have a certified A/B operator assigned and conducting the 30-day inspections. Violation 409.B[l] (Level C) (TID# 36248) (1 occurrence per tank) Failure to have Class A/B Operator perform monthly inspections. Solution: provided a list of designated A/B operator per site, along with current NMED approved trainer certificate within 30 days of receipt of this report. Site has previously been issued a violation Report#2320210320096 & #27202003110008.
Case Number: 34 20220810 0027Facility ID Number: 31336 of 6Page 6
J. Periodic 30-Day Walk Thru Inspections of the tank have not been conducted to meet monitoring requirements for release detection as required in 20.5.110.1008 NMAC. Violation 1008.A (Level C) (TID# 36248) (1 occurrence per tank). Inspections must be performed on or before 30-days and documentation must be kept for these inspections. Previously issued violation report# 27202003110008.
K. Emergency Response Signage: Site did have Emergency Response Signage posted at facility.
L. Emergency Stop: Easily accessible and clearly labeled.
14. Closing Conference and Signatures.
Closing Conference Date: Nov 21, 2022 Closing Conference Time:
Compliance Officer's Signature Date
11/21/2022
Compliance Officer - Print Name
Claudia K. Guillen
Owner or Representative's Signature DateOwner or Representative - Print Name Scott Dorton
Owner or Representative - Print Title E-mail Address james.dorton.2@us.af.mil
Facility Number:Facility Name:
Picture Number:
Photographer:
Date: Time:
Description:
Picture Number:
Picture Number:
Photographer:
Photographer:
Date:
Date:
Description:
Description:
Time:
Time:
31336Holloman Bldg#1166
Claudia K. Guillen
Aug 10, 2022 11:34 AM
Double Wall, Galvanized Steel Tank /Under Dispenser Containment.
Claudia K. Guillen
Claudia K. Guillen
Aug 10, 2022
Aug 10, 2022
Spill Bucket, Overfill Protection Clock Gauge, Alarm does not work.
E-stop.
11:35 AM
11:24 PM
2022 Annual Leak Detection Testing Report of Five Sections of F-24 Pipelines
Holloman Air Force Base, New Mexico
Prepared for:
Defense Logistics Agency Energy and United States Army Corps of Engineers
Prepared by
13 June 2022
Prepared under:
USACE Contract W9128F20D0028, Task Order W9128F22F0029
2022 Annual Leak Detection Testing Report of Five Sections of F-24 Pipelines
Holloman Air Force Base, New Mexico
Prepared for:
Defense Logistics Agency Energy
Fort Belvoir, Virginia
Prepared under:
United States Army Corps of Engineers
Contract W9128F20D0028, Task Order W9128F22F0029
Prepared by:
EA Engineering, Science, and Technology, Inc., PBC –
Michael Baker International Joint Venture
Hunt Valley, Maryland
13 June 2022
Project 187393/4.1.144 Page i EA-Baker Joint Venture 13 June 2022
Holloman AFB, New Mexico 2022 Annual Leak Detection Testing Report of Five
TABLE OF CONTENTS
Page No.
LIST OF ABBREVIATIONS AND ACRONYMS ...................................................................................... ii
PROFESSIONAL ENGINEER CERTIFICATION .................................................................................... iii
EXECUTIVE SUMMARY ......................................................................................................................... iv
1.0 INTRODUCTION
1.1 Purpose of Project
1.2 Site Background and History
1.3 Historical Testing Results
1.4 Project Scope
1.5 Project Team
1.6 Qualifications and Technical Approach
2.0 TESTING RESULTS
3.0 CONCLUSIONS AND RECOMMENDATIONS
3.1 Conclusions
3.2 Recommendations
List of Tables
Table 1-1: Project Summary
Table 2-1: Results Summary
List of Figures
Figure 1-1: Holloman AFB Overview
Figure 1-2: East Side/GAF Facility Fuel Facility and Bulk Storage Overview
Figure 1-3: Transfer Line Overview
List of Appendices
Appendix A Hansa Consult of North America, LLC Test Report
Page ii
LIST OF ABBREVIATIONS AND ACRONYMS
AFB Air Force Base AST Aboveground storage tank
BMP Best Management Practice
CMP Centrally Managed Program
DBBV Double-block and bleed valve DLA Defense Logistics Agency
EA-Baker JV EA Engineering, Science, and Technology, Inc., PBC - Michael Baker
International Joint Venture
F-24 Commercial aviation fuel with military additives
GAF German Air Force gph gallons per hour
HCNA Hansa Consult of North America, LLC
MDLR Minimum detectable leak rate
NWGLDE National Work Group on Leak Detection Evaluations
PD Probability of detection PFA Probability of a false alarm PLDS Permanent leak detection system POC Point(s) of contact psi pounds per square inch
TFS Truck fill stand TOL Truck offload
USACE United States Army Corps of Engineers
Page iii
PROFESSIONAL ENGINEER CERTIFICATION
2022 Annual Leak Detection Testing Report of Five Sections of F-24 Pipelines
Holloman Air Force Base, New Mexico
This report has been reviewed by a professional engineer and has been prepared in accordance with good engineering practices. Laboratory results, field notes, and supporting data have been reviewed and referenced correctly.
I hereby certify that I have examined this report and attest that it has been prepared in accordance with good engineering practices.
Engineer: Christopher D. Caputi, P.E.
Registration Number: 032382
State: Virginia
Date: 13 June 2022
Page iv
EXECUTIVE SUMMARY
The scope of this project is to perform the annual leak detection testing of five sections of commercial aviation fuel with military additives (F-24) pipelines at Holloman Air Force Base (AFB), New Mexico. The leak detection testing of the F-24 pipelines is performed in accordance with the Defense Logistics Agency
(DLA) Energy Leak Detection Centrally Managed Program (CMP) pollution prevention Best Management
Practice (BMP).
The annual leak detection testing of five sections of F-24 pipelines was performed by Hansa Consult of
North America, LLC between 16 and 17 May 2022, with no detectable leak above the test methods’ minimum detectable leak rates, resulting in passing tests.
In accordance with the DLA Energy Leak Detection CMP pollution prevention BMP, annual leak detection testing of the five F-24 pipelines at Holloman AFB, New Mexico should be initiated on or before the anniversary date of 16 May 2023.
The environmental regulatory compliance of this site is the responsibility of the base and the service.
Holloman, New Mexico 2022 Annual Leak Detection Testing Report of Five
1.0 INTRODUCTION
1.1 Purpose of Project
In support of the Defense Logistics Agency (DLA) Energy, the United States Army Corps of Engineers
(USACE) contracted the EA Engineering, Science, and Technology, Inc., PBC - Michael Baker
International Joint Venture (EA-Baker JV) through USACE Contract Number W9128F20D0028, Task
Order W9128F22F0029, to perform the annual leak detection testing of five sections of commercial aviation fuel with military additives (F-24) pipelines at Holloman Air Force Base (AFB), New Mexico. The leak detection testing of the F-24 pipelines is performed in accordance with the DLA Energy Leak Detection
Centrally Managed Program (CMP) pollution prevention Best Management Practice (BMP).
1.2 Site Background and History
Holloman AFB is located approximately six miles southwest of Alamogordo, New Mexico in Otero
County. Fueling operations are under the Air Education and Training Command. The fueling system at
Holloman AFB includes three major facilities: Bulk Storage, East Side Facility (also referred to as the
German Air Force [GAF] Facility), and West Side Facility.
At Bulk Storage, F-24 is received by both off-base commercial pipeline and over-the-road transport at one truck offload (TOL). F-24 is stored in two field-constructed vertical aboveground storage tanks (ASTs)
(AST 14 and AST 22). F-24 is issued via two truck fill stands (TFSs) or transferred via the on-base underground transfer line to the East Side and West Side Facilities.
At the East Side Facility, F-24 is received via the transfer line from Bulk Storage and stored in four shop-fabricated horizontal ASTs (AST 24, AST 25, AST 26, and AST 27). F-24 is issued via two TFSs or the
East Side Facility hydrant loop which is temporarily out-of-service.
At the West Side Facility, F-24 is received from the on-base transfer pipeline from Bulk Storage or at two
TOLs. F-24 is stored in two field-constructed vertical ASTs (AST 6-1 and AST 7-2). There is one aboveground product recovery tank. F-24 is issued via two TFSs or the West Side Facility hydrant loop which is temporarily out-of-service.
The F-24 fuel system includes one permanent leak detection system (PLDS) (West Side Facility PLDS
Hansa Consult of North America, LLC [HCNA]) that is utilized to perform leak detection testing of one pipeline section at the West Side Facility. Currently, the hydrant loop, located at the West Side Facility, is isolated and temporarily out-of-service from the truck fill loop. The hydrant loop will be included in the one section monitored by the PLDS once the system is back in service. The testing and certification of the
PLDS is documented in a separate report.
1.3 Historical Testing Results
The annual leak detection testing of five sections of F-24 pipelines was most recently performed under the
DLA Energy Leak Detection CMP by Vista Precision Solutions Detection, Inc., between 17 and 18 May
2021, with no detectable leak above the test methods’ minimum detectable leak rates (MDLRs), resulting in passing tests.
1.4 Project Scope
The scope of this project is to perform annual leak detection testing of five sections of F-24 pipelines at
Holloman AFB, New Mexico.
Table 1-1 provides a project summary. Figure 1-1 provides an overview of Holloman AFB. Figure 1-2 provides an overview of the East Side Facility and Bulk Storage, and Figure 1-3 provide an overview of the Transfer Line.
Table 1-1: Project Summary
Fuel System Test Section Designation Diameter
(inches) Length (feet)
Total Length (feet)
Volume (gallons) Comments
Bulk Aviation
1 Bulk Storage:
AST 14 & 22
Issue & Truck Fill Stands 4 &
6 16
576 1,479
Due to lack of thermal relief, the isolated segments of pipe outside the test limits were monitored for thermal pressure. Excessive thermal pressure was relieved by draining and collecting product from the high point vent.
2 8 560
3 Bulk Storage:
Truck Offload 6 381 381 572 Air vented through valve12-144-1.
4 Transfer Line (Bulk Storage –
GAF – West Side)
6 650 12,970 32,993
GAF/East Side Facility branch line isolation valve is now normally open. Square drive tool required to open valve pit cover for inspection. 5 8 12,320
West Side:
Truck Offload 6 95 95 143 None
GAF: Truck Fill
Stand 6 109 109 164
Pressure gauge isolation at connection point does not hold tight, leak by observed when re-installing pressure gauge.
Holloman AFB, New Mexico 2022 Annual Leak Detection Testing Report of Five Sections of F-24 Pipelines
Figure 1-1: Holloman AFB Overview
Figure 1-2: East Side/GAF Facility and Bulk Storage Overview
Figure 1-3: Transfer Line Overview
1.5 Project Team
The EA-Baker JV subcontracted HCNA to perform the annual leak detection testing. Field oversight, coordination with facility fuel representatives, quality assurance/quality controls, and final report preparation and submission were provided by EA-Baker JV personnel.
1.6 Qualifications and Technical Approach
The leak detection testing in this report was performed to detect leaks above the MDLRs at the normal operating pressure or greater, in accordance with the test method listed with the National Work Group on
Leak Detection Evaluations (NWGLDE) as described below.
The testing equipment used is that defined as the HCNA Pipeline Leak Detection System, Versions 2.0 and
2.1. Determination of leakage is based on the criteria established in the Ken Wilcox Associates, Inc. third-party evaluations as listed by the NWGLDE.
• HCNA Pipeline Leak Detection System, Version 2.0 is certified with a capability to detect leaks at a rate of 0.002 percent of the pipeline volume per hour, with a probability of detection (PD) greater than 95 percent and a probability of a false alarm (PFA) less than 5 percent for pipeline capacities
5,000 gallons and greater.
• HCNA Pipeline Leak Detection System, Version 2.1 is certified with a capability to detect leaks at a rate of 0.068 gallons per hour (gph) with a PD of 95 percent and a PFA of 5 percent for pipeline capacities less than 5,000 gallons.
2.0 TESTING RESULTS
The HCNA test report is provided in Appendix A.
The annual leak detection testing of five sections of F-24 pipelines was performed by HCNA between 16 and 17 May 2022, with no detectable leak above the test methods’ MDLRs, resulting in passing tests.
The results summary is provided in Table 2-1.
Table 2-1: Results Summary
Fuel System
Test Section Designation Length
(feet) Volume (gallons)
Certified
MDLR1
(gph)
Reference Pressure2
(psi)
Test Date Result
Bulk Aviation
Bulk Storage: AST 14 & AST 22 Issue & Truck Fill Stands
4 & 5
576 1,479 0.07 150 16 May 2022 Pass
2 Bulk Storage: Truck Offload 381 572 0.07 175 16 May
2022 Pass
Transfer Line (Bulk
Storage – GAF – West Side)
12,970 32,993 0.66 200 17 May 2022 Pass
4 West Side: Truck Offload 95 143 0.107 200 17 May
2022 Pass
5 GAF: Truck Fill Stand 109 164 0.07 150 17 May
2022 Pass
Table Notes:
psi = pounds per square inch
1. MDLR data is rounded to the hundredth decimal place.
2. Basis of reference pressure: pump deadhead or thermal relief valve pressure provided by base personnel.
3.0 CONCLUSIONS AND RECOMMENDATIONS
3.1 Conclusions
The five sections of F-24 pipelines passed the 2022 annual leak detection testing.
3.2 Recommendations
In accordance with the DLA Energy Leak Detection CMP pollution prevention BMP, annual leak detection testing of the five F-24 pipelines at Holloman AFB, New Mexico should be initiated on or before the anniversary date of 16 May 2023.
The environmental regulatory compliance of this site is the responsibility of the base and the service.
EA-Baker Joint Venture Testing Report
Holloman AFB, New Mexico
APPENDIX A
HANSA CONSULT OF NORTH AMERICA, LLC TEST REPORT
DLA Energy Leak Detection Centrally Managed Program
Perform Certified Pipeline Leak Detection Testing at Holloman
AFB, NM.
TEST REPORT
Submitted To: Michael Baker International, Inc.
Contract No: W9128F20D0028 Delivery Order: 187393 Task: 4.1.144 May 28, 2022
Submitted by:
Hansa Consult of North America, LLC
200 International Drive, Bldg. 120 Portsmouth, N.H. 03801 info@hcna-llc.com www.hcna-llc.com
A nn ua l R ep or t –
HCNA Pipeline Testing Site: Holloman AFB, NM.
May 28, 2022 HCNA Project 22-2033 Page 2 of 11
The information provided in this report is private, confidential, and should not be disclosed, copied, or provided to anyone other than the client without the express written consent of HCNA, LLC.
Hansa Consult of North America, LLC Portsmouth, NH
May 28, 2022
Prepared for:
272 Bendix Road Suite 400 Virginia Beach, VA. 23452
Telephone: 757.631.5490
FAX: 757.463.1304
Prepared and Submitted by:
200 International Drive Building 120 Portsmouth, N.H. 03801
Telephone: 603.422.8833
FAX: 603.422.8865
May 28, 2022 HCNA Project 22-2033 Page 3 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client without the express written approval of HCNA LLC
List of Contents
1 INTRODUCTION
1.1 Purpose of Inspection
1.2 Testing Criteria
2 SITE AND EQUIPMENT DESCRIPTION
2.1 Test Procedures
2.2 Test Sections
2.3 Test Fluid Specifications
2.4 Description of Facility
2.5 Set-up and Testing
3 SYSTEM CERTIFICATION
4 HCNA PRESSURE STEP TEST METHODOLOGY
4.1 Overview
4.2 Evaluation of Test Results
4.3 Criteria for Classification of Tightness
5 RESULTS / CONCLUSIONS
5.1 Test Assessment Methods
5.1.1 Visual Inspection
5.1.2 HCNA Pressure-Step Leak Detection Test
5.2 Mechanical Work / Test Notes
5.3 Problems Encountered
6 RECOMMENDATIONS
7 HCNA Technology Approvals
APPENDIX A: TEST SECTION DETAILS ........................................................................... A
APPENDIX B: SITE SPECIFIC INFORMATION ................................................................. B
APPENDIX C: TEST CERTIFICATION REPORTS ............................................................. C
APPENDIX D: CONFIGURATION DRAWING(S)................................................................ D
May 28, 2022 HCNA Project 22-2033 Page 4 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
1 INTRODUCTION
Hansa Consult of North America, LLC (HCNA) has been tasked by Michael Baker International, Inc.
to perform pipeline testing at Holloman AFB, NM. Testing was conducted under delivery order 187393
4.1.144. This delivery order provides for HCNA to conduct tightness testing and certification utilizing the third-party certified HCNA Leak Detection System. The testing and certification for Holloman AFB, NM. was conducted May 16-17, 2022.
1.1 Purpose of Inspection
The purpose of the testing and certification was to perform tightness testing on Defense Logistics Agency Energy (DLA-E) capitalized systems as a DLA Energy Leak Detection Centrally Managed Program.
1.2 Testing Criteria
Certified Tightness Testing of the identified piping at Holloman AFB, NM. is performed under the direction of DLA-E – specifically in accordance with the DLA Energy Leak Detection Centrally Managed Program.
2 SITE AND EQUIPMENT DESCRIPTION
2.1 Test Procedures
The HCNA Leak Detection System is based on the Pressure Step method, which meets or exceeds the highest national and international standards and is capable of detecting a leak of 0.068 gallons per hour or 0.00078% of line volume contingent upon segment size and at a reference pressure of 145 psi, with a probability of detection (PD) > 95% and probability of false alarm (PFA) < 5% as per Ken Wilcox Associates, Inc. Third Party Certifications. Additionally, these methods were successfully evaluated at leak rates identified in 40 CFR 280.252 2015 EPA UST regulations. HCNA provided testing of pressurized underground fuel pipeline sections at this location (See Table 1 for details). Test section results were recorded, assessed, and certified by HCNA - section specific MDLR are included in Section 5.0 (see Table 2 for details) and test certification report appendix. Test sections pipe dimensions and volumes were reviewed and confirmed with Holloman AFB, NM.
personnel or measured by HCNA staff during testing and certification. A general description of the piping layout is provided in Section 2.4.
2.2 Test Sections
The test segment number and associated pipeline description for the test sections were as follows:
SECTION
NO. DESIGNATION PIPELINE
MATERIAL
PIPELINE
SCHEDULE
PIPELINE LENGTH [ft] TOTAL
LENGTH
[ft] 2” 4” 6” 8” 10” 12” 16”
1 Bulk Storage: Tank 14 & 22 Issue & Truck Fill Stands 4&5 CS STD. 16 560 576
2 Bulk Storage: Truck Off Load CS STD. 381 381
3 Transfer Line: Bulk Storage- GAF-West Side CS STD. 650 12,320 12,970
4 West Side: Truck Off Load CS STD. 95 95
5 GAF: Truck Fill SS STD. 109 109
TOTAL: 1,251 12,880 14,131
Table 1: General Pipeline Configuration Data of Fuel System @ Holloman AFB, NM.
May 28, 2022 HCNA Project 22-2033 Page 5 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
2.3 Test Fluid Specifications
Testing was conducted using F-24 (Jet-A) as the test medium for each respective pipeline section at Holloman AFB, NM.
2.4 Description of Facility
The testing consists of initial pipeline leak detection testing of fourteen thousand one hundred thirty-one (14,131) feet of pipeline at Holloman AFB, NM.
The tested piping includes three major facilities: Bulk Storage, German Air Force (GAF) facility, and the West Side facility. The bulk storage facility consists of two above ground storage tanks (14 and 22), two truck fill stands (4 and 5), a transfer pump station, and a truck offload rack. The Bulk storage facility receives product via pipeline into storage tanks 14 and 22. Additionally, product can be received by truck through the offload rack. The six-inch offload rack line runs through Filter/Separator (F/S) 10 and tees into the pump discharge of truck fill stands 4 and 5 before going below ground; it runs for approximately 195’ below ground and comes above ground inside the tank 14 containment area. The line tees to tank 14 and enters the east side of tank 22. The tank 14 and 22 issue lines are combined at a manifold inside the tank 22 containment area and issue product to either the transfer pump station or the pumps at truck fill stands 4 and 5. The eight-inch transfer line exits the north side of the bulk storage transfer pump station running Northwest, at the end of Delaware Ave. It turns to the west, north of Bldg. 288 it tees (reducing to 6”) to service the GAF facility. After crossing the runway, the line comes above ground at the West Side facility type III Pumphouse.
The length of the pipeline was calculated from provided documents as well as on-site personnel knowledge and measurements by HCNA personnel. The piping diameter for the tested piping systems range from 6” to 8”.
2.5 Set-up and Testing
The test set-up, execution, and dismantling were conducted May 16-17, 2022. Specific tables and photographs detail each section and are provided in Appendix A.
After each HCNA Leak Detection System test, a hardcopy of the test report was produced, indicating the test result and the specific test data (one page per section tested). These incorruptible test reports have been archived for future reference (e.g., requests from authorities). No HCNA test results can be deleted or altered without deleting the entire database. The HCNA LDS computer stores all relevant data and results. An example of a test report is included below in Figure 1:
Figure 1: HCNA Leak Detection Test Report for Test Section Located at Holloman AFB, NM.
May 28, 2022 HCNA Project 22-2033 Page 6 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
All equipment required to conduct the HCNA Leak Detection System tightness test is mounted within the mobile trailer, (please refer to figure 2). This equipment includes: a jockey pump, connection hoses, pressure transmitter, data interface, the control and evaluation unit, laptop computer, as well as trailer mounted fuel holding tank for test segment pressurization/depressurization. All electrical components associated with the trailer skid are explosion-proof (Class I Div I) from the National Electrical Code (NEC), and the trailer is equipped with an onboard generator to provide power for all components. The trailer unit was independent from the local infrastructure during the tests. Fuel quality is guaranteed by the fact that all metal parts are made of stainless steel. (Please see Figures 2-7.)
Using the pump provided in the trailer, the system was pressurized to the high cycle test pressure, and the system was visually inspected for leaks. If no drips, seeps, etc. were identified, HCNA Pressure Step leak testing commenced. A similar procedure was performed for each individual test section. Accordingly, the valve configuration used for each can be assumed satisfactory; otherwise, the system would not have held pressure during the test.
Leak simulations were performed as part of the certification process. (Please refer to Figure 7 below)
Following the tightness testing for each section, test equipment was disconnected and all fluid from hose connections was collected. Lastly, site personnel were notified at the completion of the testing and insured all valves were returned to their original positions.
Detailed test section specifications, results, and photographs are provided in Appendices A- D. The information is presented and delineated by test section.
May 28, 2022 HCNA Project 22-2033 Page 7 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
Description Figure Mobile Test Trailer (typical) 2 Mobile Trailer Device Control Screen 3 Mobile Trailer PLC and Communication 4 Mobile Trailer Laptop 5 Mobile Trailer Test Connection (typical) 6 Mobile Trailer Leak Simulation 7
6 7
May 28, 2022 HCNA Project 22-2033 Page 8 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
3 SYSTEM CERTIFICATION
Hansa Consult of North America, LLC utilizing the HCNA mobile trailer unit, certified the underground fuel piping at Holloman AFB, NM. Certificate pages are provided in Appendix C.
4 HCNA PRESSURE STEP TEST METHODOLOGY
4.1 Overview
The HCNA Leak Detection System (LDS) uses the Pressure-Step methodology which is a differential pressure method for determining the tightness of any given isolated pipeline(s). The HCNA LDS measures pressure over time, where the pressure changes are converted to volume changes using the specific data from the pipeline being tested. After the test is conducted, the tightness of the pipeline is determined by evaluation of the measurement results and is expressed in gallons/hour.
Figure 8: Hansa Consult of North America - LDS Normal Pressure-Step Test Sequence
The HCNA LDS Pressure Step Test Sequence consists of five cycles:
Cycle I: The pressure of the test section (isolated pipeline) system is lowered to a defined pressure level of approximately 45 psi. Here, the pressure undergoes a short settling period before pressurizing to Cycle II.
Cycle II: The pressure of the test section is raised to the high-pressure test level. The high-pressure level is adjusted to a pressure level of approximately 145 psi. The system is closed absolutely tight after having reached this pressure. The measured pressure values are recorded by the HCNA equipment for a defined period after a pre-set settle time is elapsed.
Cycle III: The pressure in the fuel system is automatically lowered to a low-pressure level of approximately 45psi. After the system stabilizes during the pre-set settling time, HCNA equipment again records the pressure values.
Cycle IV: For evaluation purposes the same procedure as in Cycle II is executed.
Cycle V: The computer evaluates the recorded test data, calculates a respective leak rate and displays the result of the test. If the leak rate is within limits of the minimum detectable leak rate (MDLR), the result is indicated as PASSED. If the leak rate is outside the MDLR, it is indicated accordingly.
May 28, 2022 HCNA Project 22-2033 Page 9 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
The results of the test are printed out in a protocol for future reference. All data are stored in the HCNA computer. An HCNA Pressure Step tightness test with all five cycles requires approximately 45 minutes depending on site-specific circumstances. At the conclusion of the testing activities, the fuel system can be returned to normal operations.
4.2 Evaluation of Test Results
The determination of a leak is most influenced by temperature and pressure changes during testing.
The Pressure Step method is based on the physical fact that given a defined leak size, the leak rate would be proportionately larger at higher pressure than at lower pressure. Because the leak rate is directly related to a change in pressure, it can be determined from the pressure gradients during the test, whether the system is or is not tight. The HCNA Pressure-Step program compares the pressure curves of the different pressure levels (cycles) and determines the resulting leak rate results.
Assuming ideal conditions, the pressure distributions during each data recording cycle shown in Figure 9 would be horizontal and parallel. However, temperature and other external effects result in ascending or descending characteristics. If the system is not tight, the rate of leak will be higher at the high-pressure test than at the low–pressure test. As a result the pressure curves would no longer run parallel.
It is important to note that despite the significant influence temperature change has on pressure – and therefore on the leak determination – the HCNA Leak Detection System method does not require temperature measurement. Any temperature influences are addressed by application of the pressure-step methodology itself.
Using the Pressure Step methodology, HCNA is able to determine the leak rate based on the specific properties of the material and geometry of the piping system being tested. The evaluated test results are recorded in a statistical database. The reliability of HCNA’s method can be verified at any time through controlled, manually created leak simulation tests.
4.3 Criteria for Classification of Tightness
The determination of tightness of the tested pipe is based upon the resultant leak rate determined by the Pressure-Step Test.
PASS: Test results were within the stated MDLR.
FAIL: Test results exceed the stated MDLR and/or an unsatisfactory result was observed.
5 RESULTS / CONCLUSIONS
5.1 Test Assessment Methods
The pipeline test sections were assessed by one or more of the following methods:
Figure 9: HCNA LDS Data Recording Period Distribution
May 28, 2022 HCNA Project 22-2033 Page 10 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
5.1.1 Visual Inspection
Any exposed pipe, fittings and other appurtenances were visually inspected for evidence of leakage.
Additionally, each of the sections were travelled to confirm the overall directional run of the pipeline and provide inspection as required of valve pits, high and low points.
5.1.2 HCNA Pressure-Step Leak Detection Test
The underground/aboveground fuel piping at Holloman AFB, NM. was certified employing the HCNA Pressure-Step test methodology. In accordance with the US EPA Third Party Certifications, the National Work Group on Leak Detection Evaluations (NWGLDE), and the above stated “Criteria for Classification of Tightness”, all sections passed the tightness certification test. Results are summarized and provided below:
SECTION
NO. DESIGNATION
TOTAL
LENGTH
[ft]
SECTION
VOLUME
[gal]
REFERENCE
PRESSURE
[psi]
CERTIFIED
MDLR
[gal/h]
HCNA LDS
[VERSION]
TEST DATE RESULT
1 Bulk Storage: Tank 14 & 22 Issue & Truck Fill Stands 4&5 576 1,479 150 0.07 V2.1 05/16/2022 PASS
2 Bulk Storage: Truck Off Load 381 572 175 0.07 V2.1 05/16/2022 PASS
3 Transfer Line: Bulk Storage-GAF- West Side 12,970 32,993 200 0.66 V2.0 05/17/2022 PASS
4 West Side: Truck Off Load 95 143 200 0.07 V2.1 05/17/2022 PASS
5 GAF: Truck Fill 109 164 150 0.07 V2.1 05/17/2022 PASS Table 2: Leak Detection Sections Test Results @ Holloman AFB, NM.
5.2 Mechanical Work / Test Notes
Please see Appendix A for a detailed description of our testing activities. Noteworthy aspects of our testing are summarized as follows:
SECTION
NO. DESIGNATION TEST DATE TEST NOTES
1 Bulk Storage: Tank 14 & 22 Issue & truck Fill Stands 4&5 5/16/2022
It was necessary to monitor the isolated portions of the system for excessive pressure build-up. Small amounts of product were drained and collected from the high point while isolated.
2 Bulk Storage: Truck Offload 5/16/2022 BV15 & BV33 have been replaced with DBBVs, yet we tested to DBBV MOV 12-144-1 to retain testing consistency and to vent thru its bleed port. All body bleed ports were closed on older DBBV valves.
3 Transfer Line: Bulk Storage-GAF- West Side 5/17/2022 The GAF Branch line isolation valve is now normally open. Square drive tool required to open IVP cover for inspection.
4 West Side: Truck Off Load 5/17/2022 none
5 GAF: Truck Fill 5/17/2022 Pressure gauge isolation at connection point does not hold tight, leak by observed when re-installing pressure gauge.
Table 3: Test Notes on Leak Detection Test Sections @ Holloman AFB, NM.
5.3 Problems Encountered
No problems were detected at the time of testing.
6 RECOMMENDATIONS
No recommendations currently.
May 28, 2022 HCNA Project 22-2033 Page 11 of 11
The information provided in this report is private, confidential and should not be disclosed, copied or provided to anyone other than the client
7 HCNA Technology Approvals
The HCNA Leak Detection System technology utilized for this project at Holloman AFB, NM. have been recognized and approved by the following authorities:
U.S. EPA Third Party Certification: Ken Wilcox Associates Evaluation of the Hansa Consult of North America, LLC Pipeline Leak Detection System, Version 2.0—Final Report.
December 15, 2005.
U.S. EPA Third Party Certification: Ken Wilcox Associates Evaluation of the Hansa Consult of North America, LLC Pipeline Leak Detection System, Version 2.1—Final Report. May 24, 2010.
U.S. EPA Third Party Certification: Ken Wilcox…
This is the start of the file's text. The full file is on GovTribe.
File details come from the government source that posted it. Updated .