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