Overfill Equipment Inspections, Containment Sump and Spill Bucket Testing Edward S. Kubinsky Jr. CROMPCO, LLC Director of Regulatory Affairs, Training and Certification ed.kubinsky@crompco.com ASTSWMO UST Workshop Louisville, KY 05/24/2017

Overfill Equipment Options: 1. Ball Floats (aka vent valves or flow restrictors) 2. Flapper Valves (aka overfill drop tubes or automatic shutoff devices) 3. High Level Alarms (aka external audible/visual alarms)

Overfill Equipment Options

How to Inspect?

Chapter 7: Overfill Prevention Device Inspection and Testing

Overfill Prevention: Flapper

Overfill Prevention: Flapper RP 1200: Remove and inspect for damage Float moves freely Latch mechanism works Bypass valve open Verify 95% level shutoff

From OPW Presentation – NEWIPCC Webinar on 5/10/17

Problems….

Pass/Fail

Overfill Prevention: Ball Float

Overfill Prevention: Ball Float RP 1200: Remove ball float & inspect Check ball for holes or cracks Check vent hole Check for 90% level Visually verify tank-top fittings are vapor-tight Recommends removal of ball floats

Problems….

Overfill Prevention: Ball Float

Pass/Fail

Overfill Prevention: Alarm

Overfill Prevention: Alarm RP 1200: Compare ATG fuel level to stick level Check that overfill alarm is “on” Activate overfill alarm Remove ATG probe Move float to activate alarm Check float height is at 90%

Pass/Fail

Documentation Some States have developed forms (NC): PEI RP 1200 provides sample forms:

Questions/Comments?

Chapter 6: Covers Spill Bucket and Containment Sump Testing

Spill Bucket Testing Testing spill buckets for tightness: 1st routine test is not yet required in most states because EPA regs have not yet been adopted. Some states are moving with new regs already… SC – 1st test by 5/26/20 NC – 1st test by 10/13/18 MO – 1st test by 1/1/20 When EPA regs go into effect, test according to: manufacturer’s guidelines, PEI RP 1200 or state standard (if developed).

Spill Bucket Testing SW spill buckets tested at installation and at least every 3 years (annual in MD) DW spill buckets that are routinely monitored do not need to be tested (except MD) Testing not required for stage I vapor recovery spill buckets (per EPA) and (except MD)

Spill Bucket Test (Primary): Hydrostatic

RP 1200 Spill Bucket Test (Primary): Hydrostatic Clean, inspect and repair defects Fill cap and adapter must seal tightly (or use plumber’s plug) Drain valve leak tight (or permanently removed) Fill with water to within 1.5 inches of top Measure water depth to within 1/16 inch Wait one hour Water level must drop less than 1/8 inch

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Some Buckets Are Difficult to Inspect…

Some Buckets Are Difficult to Inspect…

Some Buckets Are Difficult to Inspect…

Fill to Within 1.5” of the Top of the Bucket

Test Documentation: PEI RP 1200 Provides Sample Forms

Spill Bucket Test (Primary): Vacuum Test

RP 1200 Spill Bucket Test (Primary): Vacuum Test Clean, inspect and repair defects Fill cap and adapter must seal tightly (or use plumber’s plug) Drain valve leak tight (or permanently removed) Seal test cover to top of spill bucket Apply vacuum of 30 inches water column Hold for one minute If ending vacuum is 26 inches or greater, test passes

Spill Bucket Test (Primary): Vacuum Test

Spill Bucket Test (Primary): Vacuum Test

Spill Bucket Test (Primary): Vacuum Test

What About DW Buckets. Test of Primary Acceptable What About DW Buckets? Test of Primary Acceptable? (MD = No) Must Test Interstitial? (MD = Yes) Your state guidance = ??

If the bucket is DW and monitored monthly = no test (per feds) FL = must test every 3 years MD = annual Your state = ???

RP 1200 Spill Bucket Test (Outer Wall): Vacuum Clean, inspect and repair defects Attach vacuum source to secondary access point Apply vacuum of 15 inches water column Hold for one minute If ending vacuum is 12 inches or greater, test passes

What About Stage I Vapor Buckets? EPA = No MD = Yes Your State = ? Why MD tests Stage I Vapor Recovery Spill Buckets….

What About Testing Spill Buckets Contained in a Sump?

Containment Sump Testing According to the new federal UST regulations, if interstitial monitoring is used for release detection, need to test SW STP and DISPENSER SUMPS for tightness at installation and every 3 years thereafter DW Sumps that are monitored monthly (with documentation) do not need periodic testing Has your state required interstitial monitoring when piping is installed after a certain date? If so, owners will have to test sumps installed after that date. If testing, follow manufacturer’s guidelines, PEI RP 1200 or state standard.

RP 1200 Containment Sump Testing: Hydrostatic Clean, inspect and repair defects Fill with water to 4” above highest penetration or sidewall seam Measure water depth to within 1/16 inch Wait one hour Water level must drop less than 1/8 inch

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Clean and Inspect Prior to Test

Piping Containment Sump Testing (Tank & UDC): PEI RP 1200

Test Documentation: PEI RP 1200 Provides Sample Forms

What about testing a sump that contains spill buckets but no piping What about testing a sump that contains spill buckets but no piping? EPA = No MA & MD = test Your state = ?

What About “Low-Level” Sump Testing?

Sump sensor programmed w/ positive shut down…

Will Your State Consider Low-Level Containment Sump Testing Will Your State Consider Low-Level Containment Sump Testing? MA DEP did in 2015!!

1st Round of Containment Sump Testing Data in MA for 2016

Containment Sump Testing Will Be Painful in the Beginning Here’s what MD test data looked like when they first started testing containment sumps back in 2005/2006 with their new rules.

Containment Sump Testing Will Be Painful in the Beginning Here’s what MD test data looked like when they first started testing containment sumps back in 2005/2006 with their new rules.

Containment Sump Testing Will Be Painful in the Beginning Here’s what MD test data looked like when they first started testing containment sumps back in 2005/2006 with their new rules.

Questions/Comments?