LOW LIQUID ALTERNATIVE TEST

[ZMiller]

If the allowable leak rate of the sump exceeds the leak rate allowed for the pressurized line the sump is supposed to contain how does anything actually make sense? If the electronic shut down monitoring device is located at the lowest point of the sump and the tank riser penetration fitting flange through sump bottom is leaking at a rate faster than the line someone needs to enlighten or mathematically reeducate me. Seems we are kind of right back where we started regarding sump testing. Inches per hour logic for a 10 gallon fill bucket or a 150 gallon piping or turbine sump? I beg to be enlightened as well.

It is obvious that no one writing sump testing protocol at PMAA has ever been in a sump or knows the difference between a turbine, transition or piping sump welded to a fiberglass tank and or a back fill supported flat bottomed sump flanged to a 4" riser.

In the interest of a station owner saving money and more importantly protecting the environment it's probably best to hydrostatically, vacuum or pressure and or inert gas test all below grade sump penetration fittings making sure they are doing what they were designed (KEEP HYDROCARBON VAPOR and LIQUID FUEL LEAK EVENTS CONTAINED and KEEP WATER OUT) to do in the first place. While testing the sumps the technician can fix the leaking penetration fitting, clean the drain valves, replace missing gaskets, X back in and or correctly reposition the required liquid alarm sensing probes.

PMAA needs to concentrate its (their) advisory expertise on Bahama Mama sausages, roller grills, mustard pretzels, hot dog bun warmers, wine display racks, handy capped parking curb access ramps, washroom trash containers, soap, hand towel and toilet paper dispensers, Slurpee machines, walk in cooler doors and canopy lighting.

[Fatmonk]

With State Cleanup Funds in place, the owner has little incentive to perform the test that best protects the environment. California will sunset our state fund in 2023. I'm curious how the insurance industry would like to see the stations that they cover tested.

[CherokeeUST]

I've always wondered about Sumps directly on top of FRP tanks. The tank curves and the tank ridges could segregate the tank bottom into quarters (or more). Would you be required to place 4 or more sump sensors in that type of sump? That would suck.

[JKING0923]

I can see both perspectives on this. However , If I were an owner I would much rather be able to put a 400 dollar sensor
in my sump opposed to having a 2000 per sump bill to do repairs. Not to mention not have lost revenue for a down dispenser.
I can CLEARLY see why a contactor/service company would feel different.

EPA developed these regulations to "save" the environment . The amount of hazardous waste produce to conduct these test
FAR out weighs the latter in my opinion.

I am just looking to see if the positive shutdown rule has been adopted in each/any state and if you are in compliance by doing so.
The EPA who started this seems to say yes.

[CherokeeUST]

As I'm sure you know, the EPA sets the baseline, so IF this is the minumum approved method of testing the sumps then states can use it if they choose. But, they can also choose to be more restrictive and require vacuum testing or hydro testing above teh penetrations.

California has been doing this for a LONG time already(~2004). Texas since 2007. Other states as well.

The amount of waste generated doing these tests can be minimal. The contractor doesn't have to use clean water ever time. And they could use vacuum testing on the sumps. (I'd be worried about vacuum tests failing though.)

The sensors still have to be tested annually to make sure they work correctly.

[ZMiller]

Hydrostaticly testing normally only requires a volume of water equal to the largest sump being tested. Typically when hydrostaticly testing a sump you pressure wash the sump before you visually pre test inspect. You enter the sump and expectently if you want the sump to pass tighten up all clamps and bulkhead college flange bolts.

A competent tester will if washing the sump prior to an inspection and test have the brains to have applied for a discharge permit that allows test water to be discharged into the storm or main sewer.

[JKING0923]

There in lies another problem.
I am responsible for many sites (compliance).
My sites are all unmanned cardlocks. Most do not have
the big MPDs as do many retail locations. They have commercial dispensers.
The only thing "entering" the sump is a hand and that is not without hitting
a conduit or product line .
We have a few locations with couple of MDPs how ever those have offset deep
or standard deep dispenser sumps that even if you can "enter" the sump you are not reaching
or working on the penetrations. Even with dispenser removal.

[Fatmonk]

Currently, secondary containment testing in California has a hierarchy:

1) Manufacturer's guidelines
2) Industry code or engineering standard
3) Approved method by a state registered engineer

The PMAA may fall into group 2, but that's debatable. Legally, if there is a manufacturer's guideline, that is the method you should be using here.

[ZMiller]

Secondary containment equipment and component test protocols initially were determined by a manufacturer(s) consensus standard. I'm sure manufactures would rather state a meaningless fraction of an inch hour rather than a gallons per hour leak rate. Brochure advertising a product that leaks looks better that way.

There are sump testers currently available that interface and plug into your laptop using latest and up to date inch and gallon leak rate algrarithems. These later than 1990 designed test platforms will correct sump wall deflection and diagnose low and high level sump wall and penetration fitting leaks in just a few minutes.

[CherokeeUST]

According to this webinar, only a few unknown states are considering allowing the PMAA method.

The purpose of RP 1200 is to provide a concise summary of general guidelines for the inspection and testing of leak detection, release prevention and overfill prevention equipment at UST facilities.

https://www.youtube.com/watch?v=j4ei49cRlkg