1. United Pump and Controls, Inc.
Staying in Compliance
Dispensing Equipment
Spill/Overfill
Presented by
Travis Benton
United Pump and Controls, Inc.
Good morning and thanks to everyone for coming today.
My name is Travis Benton, I am the OPS MGR for UPC in Suwanee, GA, where I previously served for 9 years as a Field Service Technician.
In my time as a technician, I have seen first hand the difference between proper and poor dispenser maintenance. I hope that I can share just a few tips with you today on how you can better maintain your equipment, prevent spills and save operating and maintenance costs on your fueling equipment.

2. New EPA UST Requirements
Perform Walkthrough Inspections Every 30 Days
Spill Buckets, Overfill Prevention, and Release Detection
Must Keep Records of Walkthrough Inspections
Perform Annual Inspections of Containment Sumps and Hand Held Release Detection Equipment
Spill Buckets must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring
Overfill Prevention Equipment must be inspected every 3 years
By now, everyone should be aware of the new 2015 UST Regs. Here are some of the major changes affecting spill and overfill prevention equipment.
You will now be required to perform monthly and annual inspections, and keep records of those walk thrus.
Spill buckets, containment sumps and overfill prevention equipment MUST now be tested every 3 years.

3. New EPA UST Requirements
Containment Sumps must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring
Under Dispenser Containment Sumps (UDC) are now required when installing new dispenser systems
Ball Float Valves no longer approved for overfill prevention on new UST installations
Existing Ball Float Valves can continue to be used for OFP, must be tested every 3 years
If an existing Ball Float Valve fails an operability test it must be replaced with one of the other approved overfill prevention devices (automatic shutoff device or overfill alarm)
Dispenser, Submersible Pump, and Piping Containment Sumps must be tested for tightness every 3 years.
UDC are now required whenever installing new dispensers systems, including dispenser change outs at existing UST sites.
Dispenser system means the dispenser and the equipment necessary to connect the dispenser to the underground storage tank system.
A dispenser system is considered new when both the dispenser and the equipment needed to connect the dispenser to the underground storage tank system are installed at an UST facility. The equipment necessary to connect the dispenser to the underground storage tank system includes check valves, shear valves, unburied risers or flexible connectors, or other transitional components that are underneath the dispenser and connect the dispenser to the underground piping.
EXISTING Ball Float Valves are still approved for overfill prevention, must be tested every 3 years. As long as they continue to pass tests, they are OK.
If an EXISTING Ball Float Valve fails an inspection/operability test, it must be replaced with another type of overfill prevention
Automatic Shutoff Device (flapper style drop tube)
Overfill Alarm

4. US EPA Resources
For a more thorough overview of the new requirements, I would encourage you to download and read the “Musts for UST’s” and “O/M UST’s” documents published by the EPA. I will provide a link to both of these at the end of the presentation.

5. EPA Sample Checklist Monthly Required Checks Annual Required Checks
Recommended Checks
From the EPA Operating and Maintaining UST Systems document, this check list covers what inspections are required monthly and annually, and includes some recommended inspections as well.
Required Monthly Inspections:
Visually check spill buckets and overfill equipment for damage.
Remove liquid or debris.
Check for and remove obstructions in the fill pipe.
Check the fill cap to make sure it is securely on the fill pipe.
For double-walled spill prevention equipment with interstitial monitoring, check for a leak in the interstitial area.
Check to make sure the release detection equipment is operating with no alarms or other unusual operating conditions present.
Ensure records of release detection testing are reviewed and current.
Required Annual Inspections:
Visually check containment sumps for damage and leaks
Remove liquid and debris
For double-walled sumps with interstitial monitoring, check for leaks in interstitial area
Check hand-held leak detection equipment, such as gauge sticks, for operability and serviceability.
This represents the bare minimum that is required, but I would encourage you to use a more thorough checklist which we will look at next.

6. Use PEI RP-900 as a guide for: Monthly Walkthrough Inspections Daily, Monthly and Annual Inspection Checklists in Appendix
PEI’s RP900 is an excellent resource for UST operators to use during the newly required monthly walk trough's.
It contains an appendix with Daily, Monthly, and Annual Inspection Checklists, which are also available in PDF format from the PEI website. I will provide a link at the end of the presentation.

7. This is the PEI RP-900 Monthly Checklist, it is more thorough than what is required, but is considered a best practice for maintaining a UST system and minimizing future maintenance costs.

9. Tank Pad Fill covers present, not broken or damaged.
Fill covers are identified by color and located on the correct tank.
We’ll begin our monthly walk through in the tank area, where there are several items that need to be regularly inspected and maintained.
Check your spill buckets for cracked or missing covers.
Check the surrounding concrete tank pad for settling, cracks, sinking manholes, etc.
Be sure your covers are properly color coded, per the API color codes, to prevent misfiling of your tanks.

10. No cracks, bulges or holes.
Spill Buckets
No cracks, bulges or holes.
Inspect each spill bucket for cracks, holes, or other damage.
Remove any debris or liquids and dispose of properly.
Spill buckets must now be tested every 3 years. This can be a hydrostatic or vacuum test and should be performed by a professional testing firm.
Here we have a slip on spill bucket that is badly cracked, allowing any spilled product to enter directly into the tank backfill and groundwater.
Obviously, this spill bucket would fail both a visual inspection and a precision test.

11. Fill cap in good condition, seals tightly.
Fill Pipe
Fill cap in good condition, seals tightly.
Make sure all fill caps are in place, seals are in place, and that they lock securely to the fill pipe.
Check to make sure settling concrete and collapsed spill buckets have not allowed the spill bucket lid to contact the fill cap.
Finally, check that fill adaptors are tight and in good condition to prevent leaks during deliveries. Swivel adaptors should rotate without the base unthreading from the riser.

12. Overfill Prevention – Drop Tube Shutoff
Monthly : Visually inspect for debris or obstructions in valve
3 Year Inspection:
Valve moves freely and operates according to manufacturer’s specifications.
Valve is installed to shut off flow at 95% Capacity
Sites with “flapper” style drop tubes for overfill prevention should regularly inspect the valves for obstructions while inspecting spill buckets and fill caps.
UST owners can easily perform a visual inspection by looking into the drop tube, checking for obstructions, but 3 –year inspections should be performed by a professional testing firm, who will remove the drop tube for a thorough test and inspection.

13. Overfill Prevention - Alarm
Use the “Test” button to test visual and audible alarms Keep records of test every 3 years
If your site is using an overfill alarm for overfill prevention, you should make a habit of pressing the test button during your monthly walk through inspections to test both the audible and visual alarms.
You’re only required to test this device every three years, but’s it such a quick and easy test that I recommend adding it to your monthly inspection.
Be sure to keep records of the 3 year test, but it won’t hurt to record it with your monthly tests also.
Finally, make sure to wear earplugs when you test! These are designed to be loud enough for the station operator to hear it from inside the building.

14. Overfill Prevention – Ball Float Valve
Existing Ball Floats are still allowed but must be tested every 3 years.
Failed BFV’s must be replaced with Drop Tube or Alarm
BFV’s are not easily removed and inspected during a monthly inspection, but must be removed and inspected every 3 years. This is another test best suited for a testing firm.
Must keep records of inspections for 3 years.
Existing BFV’s will still be allowed as a form of overfill prevention, but once they fail inspection they must be replaced with either a drop-tube style overfill prevention valve or an overfill alarm.

15. Any water or product removed and disposed of properly.
Containment Sumps
Any water or product removed and disposed of properly.
Submersible Turbine Pump or STP Sumps, Under Dispenser Containment Sumps and any other piping or transition sumps, should be inspected annually to ensure no product has leaked into the containment sumps, indicating a leak in the piping or at the STP.
Required Annual Inspection, Required 3 year testing.
If you find product in the sumps, the source of the leak needs to be investigated and repaired immediately! A 3rd party precision test should be performed to confirm the leak has been repaired.
Any water or product should be removed and properly disposed of. Even if it’s just water, do not simply pump it out onto the ground. Water exposed to petroleum equipment can still contain traces of petroleum product.
If you find water, the source of entry should be investigated and repaired.
A common cause of water in containment sumps is improper grades around the tank pad, settling concrete, damaged seals or gaskets, and sediment or debris between the sump collar and manhole skirt.

16. Dispenser Sumps Clean and Dry
If there has been a leak in your dispenser hydraulics, even a very slight leak, you will find product or residue in the under dispenser containment sump.
You will need to find the source of the leak, have it repaired, and then properly remove the liquid and dispose of it.
Although not common, you may find water has entered the sump. Again, please properly dispose of any water removed.
Water usually comes from pressure washing the forecourt areas. Be sure to avoid direct water pressure contact with the dispenser.
Again, required annual inspection and 3 year testing. UST owners may perform inspections but testing should be done by a testing firm.

17. Anchor bolts and dispenser frame solid and in good condition.
We’ve covered the required monthly and yearly inspections, as well as the new testing requirements. The following slides are recommendations to supplement the periodic inspections.
Adding these to your monthly and yearly inspections will ensure your equipment is properly maintained, it will help you identify issues before they lead to costly shut downs, and will save you money over the long run.
At least once a year, you should inspect the dispenser frame where it mounts to the island to make sure the anchor bolts are in place, tight, and free of rust.

18. Emergency shutoff (impact valve) anchored.
While inspecting the dispenser anchor bolts, you should also inspect the emergency shutoff valve, commonly called an impact valve or shear valve, to ensure it is properly anchored and that the shear groove is at grade level.
Emergency shutoff (impact valve) anchored.

19. Check for leaks in hydraulic area.
Next, you should thoroughly inspect for signs of leaks around the meters, valves, and filters.
Signs of a leak will be dampness on any piping or hydraulic components, discoloration, an oily residue, or liquid standing in the containment sump below the dispenser.
If you see any of these signs, you should contact your dispenser service company for repairs.
Discoloration

20. Electrical conduit, junction boxes, and wiring in good condition.
Next, inspect all electrical conduits and junction boxes. All covers should be in place, all bolts should be in place and snug, and all conduit fittings should be tight.
If you see any exposed wiring, or disconnected conduit fittings, contact your dispenser service provider immediately!

21. Hoses in good condition, no cuts, cracks, bulges, blisters, flat spots, kinks or worn spots.
After inspecting the hydraulics area, turn your attention to the exterior of the dispenser.
Check the hoses for any leaks, cracks or kinks.
Just because it’s not leaking, doesn’t mean it is safe! A badly cracked hose is just a drive-off away from a very dangerous situation where the hose may separate before the breakaway device, causing a potential release, fire, and/or injury to a customer.

22. Breakaways and swivels in good condition.
Inspect swivels and breakaways. Tell-tale signs of age are oil residue around the fittings.
Look for leaks, especially where the swivel rotates.
Always follow the manufacturer’s recommendations for reconnecting breakaways after a drive-off.
When in doubt, call your service provider to reconnect or replace your breakaways.

23. Check nozzles for good condition.
Always check your nozzles for abnormal wear, leaks, or other signs of damage.
It’s also a good idea to make sure your nozzle’s automatic shutoff device is working properly.

24. Filters clean, dry, and dated
Check length of time since last filter change.
Filters are one of the most neglected items on a fuel dispenser, and typically only get replaced when a customer complains of slow flow rates.
We recommend that all filters, on all dispensers be replaced on a regular basis. Low throughput locations can change filters once per year, higher throughput locations may need to replace them every 6 months or more.
We also recommend filters be dated and initialed, and records kept to ensure they are replaced on time.

25. Meter(s) calibrated within last 12 months.
Another highly neglected area we see is meter calibration.
We recommend that all meters on all dispensers be calibrated every 12 months. This protects both the consumer and the owner, but more often the owner!
Meter typically over deliver as they age, and the “free product” being given away can add up to thousands of dollars per year at high volume sites.
The State will check your calibration during their scheduled inspections or if a consumer complaint is made against your location, but due to their backlogs, they cannot check your meters every 12 months.
It’s best to be proactive and keep your meters calibrated on a regular basis.
We find many meters are so worn out that they cannot be calibrated, this is simply due to neglected filter changes, allowing dirty particulates to pass thru the meter damaging it beyond repair.
Meters are $150 to $300 a piece, filters are $6-$12 a piece. Just one more reason to maintain your filters and calibration!

26. If suction pump, check belts and clean strainer.
(strainer inside of pump housing)
Suction pumps have their own special maintenance requirements.
Be sure to check the drive belt for wear or cuts, and check the tension adjustment.
Inspect for evidence of leaks, especially around the air eliminator tube.
Suction pumps typically have mesh strainer screens instead of a spin on filter. These need to be removed and cleaned on a similar basis as filters.
Your suction pumps may also have an additional internal or external filter housing, and the filter needs to be replaced regularly as well.

27. Warnings and fueling instructions posted and readable.
Next, it is important to inspect the exterior of you dispensers for the proper warning labels and caution labels.
Remember the days before coffee cups were labeled “Contents may be Hot”?
Ever wonder why lawn mowers have signs showing not to put your hands under a running mower?
Make sure you’re labeled!

28. Emergency Stop Switch easy to see and accessible. Test it!
Yet another important device that is commonly neglected!
Know where your switch is!
Make sure its CLEARLY Labeled!
TEST IT!!!
If it doesn’t work, shut down your site and contact your fuel system service provider and electrician IMMEDIATELY to have it repaired.
Train your staff on its location and proper use.
Emergency Stop Switch easy to see and accessible. Test it!

29. Resources US EPA Musts for USTs November 2015
US EPA Operating and Maintaining USTs February 2016
And that concludes my presentation, I hope I have shed some light on dispenser maintenance and spill/overfill maintenance.
If you have any questions or would like additional resources, feel free to reach out to me and I would be happy to help!
Thank You…

30. United Pump and Controls, Inc.
Resources
PEI RP900
Daily, Monthly, Annual Inspection Checklists are Free to Download
Travis Benton
United Pump and Controls, Inc.