OVERVIEW OF THE NEW WALKTHROUGHINSPECTION REQUIREMENT AND TESTING
In 2015, EPA revised the underground storage tank (UST) regulations. Here are the requirements for inspections and testing.
EPA mandates: In states with SPA, none of the new requirements will apply until the state adopts the federal requirements or if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must continue to meet the state UST requirements.
OVERVIEW OF THE NEW WALKTHROUGH INSPECTIONREQUIREMENT AND TESTING
2015 FEDERAL (EPA)UST REGULATIONSImplementation Time Frames For 2015 UST Regulations
1 Note that EPA is requiring owners and operators to also submit a one-time notification of existence for these UST systems by October 13, 2018. Owners and operators must demonstrate financial responsibility when they submit the one-time notification form.2 UST systems installed after October 13, 2015 must meet these requirements at installation.
2015 Requirements Implementation Time FrameFlow restrictors in vent lines may no longer be used to meet the overfill prevention requirement at new installations and when an existing flow restrictor is replaced
Owners and operators must begin meeting these requirements after October 13, 2015
Testing following a repairClosure of internally lined tanks that fail the internal lining inspection and cannot be repaired according to a code of practiceNotification of ownership changesDemonstrating compatibilityFor airport hydrant fuel distribution systems and UST systems with field-constructed tanks:• Notification and financial responsiblity1
• Release reporting• Closure
Secondary containment and interstitial monitoring for new and replaced tanks and pipingOwners and operators must begin meeting these requirements after April 11, 2016
Under-dispenser containment for new dispenser systemsOperator training
Owners and operators must begin meeting these requirements on October 13, 2018
Site assessment records for groundwater and vapor monitoringFor previously deferred UST systems:2
• Release detection for UST systems that store fuel solely for use by emergency power generators
• Subpart K (except notification, financial responsibility, release reporting, and closure) for airport hydrant fuel distribution systems and UST systems with field-constructed tanks.
Spill prevention equipment testing2
Owners and operators must conduct the first test or inspection by October 13, 2018
Overfill prevention equipment insepctions2
Containment sump testing for sumps used for piping interstitial monitoring2
Release detection equipment testingWalkthrough inspections
WALKTHROUGH INSPECTIONS
Beginning on October 13, 2018 – Option 1: Every 30 Days:
Check spill prevention equipment Check release detection equipment and records
Annually : Check containment sumps(includes UDC) Check hand held release detection equipment
Keep records of the walkthrough inspections for at least 1 year.
Montana Implementation date: Mid year 2021
EVERY 30 DAYS
Exception to every 30 days inspection: spill prevention equipment at UST systems receiving deliveries at intervals greater than every 30 days may be checked prior to each delivery.
Spill prevention equipment inspection:
Check for damage Remove any liquid or debris Check for and remove any obstructions in the fill pipe Check the fill cap to make sure it is securely on the fill pipe Double walled spill prevention equipment with interstitial
monitoring check for a leak in the interstitial area
EVERY 30 DAYS
Release detection equipment inspection:
Ensure it is operating with no alarms or other unusual operating conditions present
Ensure records of release detection testing are reviewed and current
ANNUALLY
Containment sumps(includes UDC): Check for damage, leaks into the
containment area, or releases to the environment
Remove any liquid or debris
Double walled containment sumps with interstitial monitoring check for a leak in the interstitial area
CONTAINMENT SUMP INSPECTION
ANNUALLY
Hand held release detection equipment(for example tank gauge sticks or groundwater bailers):
Check for operability and serviceability
Option 2: Conduct walkthrough inspections according to a standard code of practice developed by a nationally recognized association or independent testing laboratory. The code of practice must check equipment comparable to option 1 above.
Option 3: Conduct walkthrough inspections according to requirements developed by your implementing agency. These requirements must be comparable to the requirements described in option 1 above.
WALKTHROUGH INSPECTIONS
Owners and Operators may conduct these inspections themselves or have a third party perform them
2015 Federal UST regulation allows a code of practice to be used instead of the specific requirements listed in the rule
PEI RP 900 listed in rule as one option The implementing agency (MT DEQ UST)
may also establish comparable walkthrough inspection requirements
WHAT’S NOT REQUIRED BY FEDERALREGULATIONS
A common misconception is that tank sumps and under dispenser containment sumps must be checked monthly. This is NOT the case.
Currently required annually. Be AWARE that many states may require this equipment to be inspected monthly. We will keep you posted.
WALKTHROUGH INSPECTIONS
Why require them?
Site Operators cannot just rely on electronic monitors.
You need to physically look at your equipment. You need to test your equipment. Problems can be discovered early
before they become biggerand more expensive!
WALKTHROUGH INSPECTION EXAMPLES
Not going to be this apparent
DROP TUBE: STICKS, CORROSION?
LOTS OF LIQUID TO REMOVE
ABSORBENT PADS: USE EM!
DISPENSER ISSUES
PIPING RUNS
SUMPS BECOMING COMPROMISED
IN ADDITION TO THESE REQUIREMENTS
Owners and operators must maintain the most recent year’s walkthrough inspection records. Records need to include a list of each area checked, whether each area checked was acceptable or needed
action taken, a description of any actions taken to correct issues, and delivery records if spill prevention equipment is
checked less frequently than every 30 days due to infrequent deliveries.
EVERY SITE IS DIFFERENT
EVERY SITE IS DIFFERENT
PEI RP 900-17:
EPA WALKTHROUGH INSPECTIONCHECKLIST
EVERY 30 Days
EPA WALKTHROUGH INSPECTIONCHECKLIST -ANNUALLY
RECORD KEEPING FOR WALKTHROUGHINSPECTIONS
• Include on the record:– A list of each area checked– Whether each area checked was OK or necessary action was taken– A description of actions taken– Delivery records if spill prevention equipment is checked less than every 30 days
•Keep records of the walkthrough inspection for at least one year
TESTING SPILL BUCKETS ANDCONTAINMENT SUMPS
Beginning on October 13, 2018 - MT DEQ has already implemented containment sump testing regulations
Option 1: Spill prevention and containment sump equipment is double walled and the integrity of both walls is monitored at least as frequently as in the walkthrough inspection requirement (typically every 30 days for spill buckets, and annually for containment sumps).
If owners and operators discontinue this periodic monitoring, they have 30 days to conduct the test described in option 2 on next slide.
TESTING SPILL BUCKETS ANDCONTAINMENT SUMPS
Option 2: Spill buckets & containment sumps used for interstitial monitoring of piping are tested at least once every 3 years. The test must determine the equipment is liquid tight by using either vacuum, pressure, or liquid testing according to one of the following:
1)Requirements developed by the manufacturer (owners and operators may only use this option if the manufacturer has developed testing requirements)2)A code of practice developed by a nationally recognized association or independent testing laboratory3)Requirements determined by the implementing agency to be no less protective than those developed by the manufacturer or in the code of practice
INTO TO PEI/RP 1200-17
PR 1200-17 Purpose:
• Protect human health and the environment
• Promote safe and reliable operation of UST systems
• Prevent spills and overfills associated with deliveries
• Prevent damage to property and equipment
Test methods based on current industry practices
Intended to demonstrate that a leak from the primary containment will be detected before it reaches the environment
Follow the regulatory requirements for each specified test procedure. RP 1200-17 describes tests in a generalized fashion.
Not meant to provide interpretation of regulatory requirements related to UST systems
RP 1200-17 SCOPE
Secondary Containment Spill Prevention
equipment Overfill Equipment Leak detection equipment Shear Valves Emergency Stops
PEI RP 1200-17 - HOW TO CONDUCTTESTING OF….
TESTING SPILL BUCKETS ANDCONTAINMENT SUMPS
Spill prevention equipment and containment sumps used for interstitial monitoring of piping installed after October 13, 2015 must be tested for liquid tightness at installation and then once every three years. Note that most installation codes of practice require testing of this equipment for liquid tightness at installation – this will qualify as the first test.
The test procedure is the same for spill buckets and containment sumps
Spill buckets and containment sumps can be single-walled or double-walled
SPILL BUCKET & CONTAINMENT SUMPTESTING
Spill Buckets- Test procedures for both single and double-walled spill buckets Single-walled = Hydrostatic OR Vacuum Test Double-walled = Vacuum test of interstice
Containment Sumps – Test procedure for single-walled containment sumps only Single-walled = Hydrostatic Test
SPILL BUCKET & CONTAINMENT SUMPTESTING
Single-Walled Spill Bucket –Hydrostatic Test Clean and examine the spill bucket Fill with water to within 1.5 inches of top Measure water depth to nearest 1/16th
inch Monitor for 1 hour
Pass = Difference < 1/8 inch Fail = Difference > or = to 1/8 inch
SPILL BUCKET & CONTAINMENT SUMPTESTING
Single-Walled Spill Bucket-Hydrostatic Test Be sure tank fill cap seals properly Be sure drain valve seals properly
If these components don’t seal properly- water may enter the tank
Alternatively, you may temporarily install a plumbers plug in the fill riser and remove/plug the drain valveto ensure tight seals.
SPILL BUCKET & CONTAINMENT SUMPTESTING
Single-Walled Spill Bucket-Vacuum Test Clean and examine the spill bucket Install special test cover Pull a vacuum of 30 ’’ H2O Column Monitor vacuum for 1 minute
Pass = Ending vacuum level > or = to 26 ’’ H20 column
Fail = Ending vacuum level < 26 inch H20 column
Note: This test does not generate any water
SPILL BUCKET & CONTAINMENT SUMPTESTING
Double-Walled Spill Bucket-Vacuum Test Clean and examine the spill bucket Pull a vacuum of 15 ” H20 column on
interstice Monitor vacuum for 1 minute
Pass = Ending vacuum > or = to 12 ” H20 column
Fail = Ending vacuum < 12 ” H20 column
SPILL BUCKET & CONTAINMENT SUMPTESTING
Double-Walled Spill Bucket-Vacuum Test
Testing the interstice of a double-walled spill bucket simultaneously test both the primary and secondary walls of the spill container.
SPILL BUCKET & CONTAINMENT SUMPTESTING
Single-walled Containment sump-Hydrostatic Test Clean, examine, and prepare the containment sump Fill with water to 4 ” above the highest sump penetration Measure water level to the nearest 1/16 inch Monitor water level for 1 hour Pass = Difference < 1/8 inch Fail = Difference > or = to 1/8 inch
SPILL BUCKET & CONTAINMENT SUMPTESTING
Hydrostatically test all containment sumps with liquid for one hour to a height 6 inches above the highest sump penetration. A passing test must show no liquid loss measured during the testing interval
MT DEQ TEST REQUIREMENTS
Must be: 6 inches above highest sump penetration!
SUMP TESTING SOLUTION- “WATERWAGONS”
Shutoff flow at: A. 95% tank capacity OR B. before tank top fittings are wettedRestrict flow at:
A. 90 % tank capacity ORB. 30 minutes prior to overfilling
Alert the operator at:A. 90% tank capacity ORB. 1 minute prior to overfilling
OVERFILL PREVENTION EQUIPMENTINSPECTIONS
Federal Rule (40 CFR 280) options
RP Committee decided to develop protocols reflective of the more conservative application of the rules
Overfill prevention devices must be set to:Shutoff at 95 % tank capacityRestrict flow at 90 % tank capacityAlert the operator at 90 % tank capacity
OVERFILL PREVENTION INSPECTION
OVERFILL PREVENTION INSPECTION
Beginning on October 13, 2018 :
owners and operators must have their overfill prevention equipment inspected for proper operation at least once every three years. Overfill prevention equipment installed after October 13, 2015 must be inspected for proper operation at installation and then once every three years.
Remove from the tank Visually inspect (is float present?) Manually operate valve to ensure it is
functional Measure length to ensure complete shutoff
occurs when the tank is no more than 95 % full
Note: Ensure that complete shutoff point occurs at 95 %
AUTOMATIC SHUTOFF DEVICES(FLAPPER VALVES)
Flapper Valves:
Remove from the tank Visually inspect Measure length to ensure flow restriction occurs
when the tank is no more than 90 % full
Note: All tank top fittings must be tight in order for the ball float valve to effectively restrict the flow.
RESTRICTION DEVICES (BALL FLOATVALVES)
Electronic Alarms typically part of the ATG system
Remove from the tank Visually Inspect Measure length to ensure that alarm occurs
when the tank is no more than 90 % full
Note: Overfill alarms must provide an audible warning to the fuel delivery driver (outside! )
ALERT DEVICES (ELECTRONIC ALARMS) HLA
Test/Inspection of the ATG system: Console In-tank probes Interstitial sensors (tanks & piping)
Test is general in nature- Not intended as calibration of the ATG system
ELECTRONIC MONITORING SYSTEMINSPECTION
ATG Console: Verify system is properly configured (setup) Verify all site specific parameters are correct Test the alarm Test the battery backup Verify that all indicator lamps function Verify that printer functions Verify that LCD display functions
ELECTRONIC MONITORING SYSTEMINSPECTION
ATG Probes: Remove probe from tank Visually inspect probe tank cap assembly Visually inspect probe and floats Verify that floats move freely Verify all floats indicate the correct fluid
levels and indicated fluid levels correspond with the programming (measured vs. ATG number)
COMPONENT TESTING & VERIFICATION
Interstitial Sensors: RP only considers sensors that function by detecting
the presence of liquids (both discriminating and non-discriminating)
RP only considers float switch type sensors as these are the most common-
For other types of sensors – consult the manufacturer
ELECTRONIC MONITORING SYSTEMINSPECTION
Interstitial Sensors: Verify that sensor is properly installed Remove sensor from tank interstice or piping sump Visually Inspect Submerge sensor in appropriate test fluid (water for
non-discriminating type) Verify proper alarm condition and/or STP Shutdown Verify sensor is properly labeled in ATG setup
ELECTRONIC MONITORING SYSTEMINSPECTION
Two Types of automatic line leak detectors
Mechanical Electronic
AUTOMATIC LINE LEAK DETECTORS
General: Test procedures verify that the ALLD is capable of
detecting a leak equivalent to 3.0 gph @ 10 psi Test apparatus must have an adjustable orifice to
properly simulate a leak equivalent to 3.0 gph @ 10 psi
Calibration of the adjustable orifice may be accomplished with or without the use of a pressure regulator
AUTOMATIC LINE LEAK DETECTORS
LDT-890 Leak Detector Tester
General: Test must confirm that the STP properly
cycles on/off (verifies STP relays are functioning)
Simulated leak must occur at the dispenser that is at the highest elevation above the STP
If piping system has master/satellite configuration, simulated leak must occur at the farthest satellite dispenser
AUTOMATIC LINE LEAK DETECTORS
Mechanical Leak Detectors: Visual inspection Verify leak detector “trips” when line
pressure nears zero Verify leak detector “sees” a
simulated leak equivalent to 3 gph @ 10 psi “slow flow” conditions exists
AUTOMATIC LINE LEAK DETECTORS
Electronic Line Leak Detectors: Visual inspection Verify system setup parameters are
correct Verify leak detector searches for leak Verify leak detector sees simulated
leak equivalent to 3 gph @ 10 psi Causes alarm condition Causes STP shutdown
AUTOMATIC LINE LEAK DETECTORS
Product Shear Valves: Visual Inspection Verify anchored securely and at
correct height Confirm trip mechanism is functional Manually close the valve poppet Verify that no product flow occurs
SHEAR VALVE INSPECTION & TESTING
Pass/Fail Criteria: Properly anchored to the dispenser box frame or
dispenser island Shear section located between ½ inch above and ½
below the level of the top surface of the dispenser island
Lever arm is free to rotate and able to snap the popet valve shut/closed
No fuel flow from the dispenser nozzle when the product shear valve is closed.
SHEAR VALVE INSPECTION & TESTING
Manually activate switch to confirm power has been disconnected to: All dispensers All STPs
All power, control and signal circuits associated with dispensers and STPs
All other non-intrinsically safe electrical equipment in the classified areas of the UST system and dispensers
EMERGENCY STOPS