Hydrostatic Sump Testing Requirements & RP1200

Underground storage tank regulations, compliance issues and news from EPA OUST, ASTSWMO, CALCUPA and state regulatory agencies.
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Pump Jockey
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Joined: Wed Nov 21, 2018 7:34 am

Hydrostatic Sump Testing Requirements & RP1200

Post by sumptester » Wed Nov 21, 2018 8:15 am

Why does RP1200 require the piping to be isolated from the sump via termination/air test fittings in order to test the sump?

Can any of you who know anyone from PEI’s RP dept, send them this email?

I asked EPA a bunch of questions. They send back the exact response that confused me and resulted in me asking the question.


When H-Testing a piping sump, all penetration must be capped for testing. If no test boots are present, is there a specific method required to isolate the interstitial space for the piping? For example, on a 3” x 2” frp DW pipe with no test boot:

>>>>>>>280.35(1)(ii)(A) requires you perform the test according to requirements developed by the manufacturer (if they have them), a national code of practice (RP1200), or the requirements determined by the implementing agency. EPA (other than our low level testing option you saw in the technical compendium) does not spell out details on the tests procedures. You must follow one of the three options listed here.


Based on their language:


Either we follow RP1200 which says termination fitting HAVE to be in place to keep water OUT of the piping DW (Which I cannot understand since you would then also be testing the most important part of the piping containment system. The piping you cannot see in direct contact with the soil.)


Follow the manufacturer’s recommendation for testing: (Obviously their h-testing procedures are for the pre-backfill testing. We test the sumps post seam and then post penetration during a new install) My questions are about the 10/13/18, existing sump testing requirements.

And based Containment Solutions figure 7-1:

According to the Cont. Solutions manual, only the bottom seam needs to be tested. I have asked them to send me an email stating that the means of “sealing penetrations and missing termination fittings” is obviously up to the tester. I also asked this of a bunch of other sump makers. I am aware we need to test above all penetrations as well.

Since they do not tell us to seal any penetrations or make sure air test boots are on the 3 x 2 frp piping, I assume that means the sealing of these items is NOT required. Commons sense tells you to seal them if they leak but if I follow the manufacturer recommendation, I just fill up the sump.

Here is another issue: What if I fill up the sump and I know water is leaking into the secondary and it never stops leaking into the secondary. Do I just seal the secondary and retest the sump? That seems insane.


It appears the DEP (implementing agency) could rule on this issue and we would be done with it.


Lastly-If we could get PEI to addend RP1200 to include the piping secondary are part of the H-Testing, this “gray area” would go away.

We should be testing the sump AND the piping’s DW. If something leaks, then isolate and determine if it is the sump or the pipe. If it is the pipe, you just averted huge potential environmental disaster from occurring.

If it is the sump, fix the sump.

Pls confirm receipt and call with any questions.

Chris Trebus
Independence Constructors
1200 Route 22E
Bridgewater, NJ 08807

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Re: Hydrostatic Sump Testing Requirements & RP1200

Post by ZMiller » Wed Nov 21, 2018 9:53 am

You have read the rules.

What a mess. Who interprets actual condition of a sump and then writes the rules?

What is an acceptable leak rate in gallons per hour for a sump being tested?
Until an actual leak rate in gallons per hour is established what good is a sump test?
When you are dead it's likely you won't know it. It could be difficult for others. It's the same if you are stupid.
"Tact is the ability to tell someone to go to Hell in a way that they will begin looking forward to the trip"

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