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

2. 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)

3. Overfill Equipment Options

5. How to Inspect?

6. Chapter 7: Overfill Prevention Device Inspection and Testing

7. Overfill Prevention: Flapper

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

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

10. Problems….

12. Pass/Fail

13. Overfill Prevention: Ball Float

14. 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

15. Problems….

16. Overfill Prevention: Ball Float

17. Pass/Fail

18. Overfill Prevention: Alarm

19. 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%

20. Pass/Fail

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

22. Questions/Comments?

23. Chapter 6: Covers Spill Bucket and Containment Sump Testing

24. 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).

25. 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)

26. Spill Bucket Test (Primary): Hydrostatic

27. 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

28. Clean and Inspect Prior to Test

29. Clean and Inspect Prior to Test

30. Clean and Inspect Prior to Test

31. Some Buckets Are Difficult to Inspect…

32. Some Buckets Are Difficult to Inspect…

33. Some Buckets Are Difficult to Inspect…

34. Fill to Within 1.5” of the Top of the Bucket

35. Test Documentation: PEI RP 1200 Provides Sample Forms

36. Spill Bucket Test (Primary): Vacuum Test

37. 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

38. Spill Bucket Test (Primary): Vacuum Test

39. Spill Bucket Test (Primary): Vacuum Test

40. Spill Bucket Test (Primary): Vacuum Test

41. 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 = ??

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

43. 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

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

45. What About Testing Spill Buckets Contained in a Sump?

46. 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.

47. 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

48. Clean and Inspect Prior to Test

49. Clean and Inspect Prior to Test

50. Clean and Inspect Prior to Test

51. Clean and Inspect Prior to Test

52. Clean and Inspect Prior to Test

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

54. Test Documentation: PEI RP 1200 Provides Sample Forms

55. 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 = ?

56. What About “Low-Level” Sump Testing?

57. Sump sensor programmed w/ positive shut down…

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

60. 1st Round of Containment Sump Testing Data in MA for 2016

61. 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.

62. 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.

63. 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.

64. Questions/Comments?