Spill Containment Device and Containment Sump Testing Protocols. Introduction

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Benedict Anthony
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1 Department of Natural Resources and Environmental Control Tank Management Branch 391 Lukens Drive New Castle, DE (302) (Phone) (302) (Fax) Spill Containment Device and Containment Sump Testing Protocols Introduction The Department of Natural Resources and Environmental Control, Tank Management Branch (DNREC-TMB) has developed this guidance document to assist tank owners, operators and contractors in complying with the requirements for spill containment device (spill bucket) and containment sump testing. Containment testing as illustrated in this document may be performed by owners, operators, and tank or testing contractors. However, these procedures must be explicitly followed, the test results must be documented, and any water used for testing must be properly disposed and documented. All of these documents must be available upon request by the DNREC-TMB. Any test failures must be reported within 24 hours, and repairs or replacements made within 30 days. Alternative methods of testing, such electronic or vacuum methods, require prior approval by the DNREC-TMB and must be performed by contractors or testers certified in their use. Spill Containment Devices All regulated UST systems are required to have spill containment devices installed around the fill pipe, and to have them annually tested. The requirements for their installation and testing are found in the UST Regulations in the sections shown in the table below: Spill Containment Device Citations Part B Part C Part D Petroleum Used Oil Heating Fuel Hazardous Substance New Existing New Existing New Existing New or Existing New = A UST System installed after January 11, Existing = A UST Systems installed before January 11, Petroleum = Any UST System that is regulated under Part B, but is not a Used Oil UST System. All New UST systems with vapor recovery (VR) installed are required to also have spill containment devices installed around the Stage I VR adapters. Existing UST systems with VR installed are not required to have spill containment devices installed around the Stage I VR adapters. VR spill containment devices on new or existing UST systems are not required to be tested; voluntary testing is always an option. Spill Containment Hydrostatic Test Procedures: 1. Prior to conducting the test, any accumulated trash, debris, or product present must be removed from the containment device and properly disposed.

(DNREC-TMB) has developed this guidance document to assist tank owners, operators and contractors in complying with the requirements for spill containment device (spill bucket) and containment sump

2 2. Any missing or damaged fill caps or adapters should be replaced prior to conducting the test. 3. Damaged containment devices should not be tested, but should instead be noted on the results sheet and reported to the DNREC-TMB in accordance with the reporting requirements listed below. 4. If the containment device contains a drain, it must be plugged using a temporary or permanent plug prior to conducting the test. If the drain cannot be made tight, the test is invalid and the containment device must be repaired or replaced. 5. Fill the containment device to the top. Please note that, if the containment device is properly installed, the fill pipe cap should be submerged. The test is not automatically invalidated if the cap is not submerged. However, the condition should be noted on the test report and must be addressed if the spill containment device is replaced at some time in the future. 6. Place a rigid straight-edge across the top of the containment device. The straight edge should be secured in place or its location marked to ensure accurate measurements. Allow the water to settle in the containment device. Using a measuring device that is accurate to 1/16 th of an inch, measure the distance perpendicular from the straight edge to the top of the water s surface, and record the result. 7. Cover the containment device, using its lid or an alternative cover, and allow the containment device to sit undisturbed for one (1) hour for an annual test. Tests for new installations or containment device replacements must sit undisturbed for 24 hours. 8. After the allotted time frame specified in #7 has elapsed, measure the height of the water level as described above. The test fails if the water level drops 1/8 th of an inch or more. 9. All water must be removed at the completion of the test. It may be re-used for testing purposes or must be properly disposed. Containment Sumps All regulated UST systems installed after January 11, 2008 are required to have containment sumps installed at the tank-top and under product dispensers. Certain piping arrangements may also require the use of transition sumps as well. Containment sumps on new UST systems and those used for release detection on existing UST systems are required to be tested every 36 months. Containment sumps used for pressurized piping release detection where there is no line leak detector or containment sumps used as a spill containment device around a fill pipe or pump-out point are required to be annually tested. Some sites may have containment sump testing requirements not listed here due to unusual configurations, variances, or specific requirements in the installation approval letter. General requirements for containment sump installation and testing are found in the UST Regulations in the sections shown in the table below: Containment Sump Citations Part B Part C Part D Installation Testing Installation Testing Installation Testing New Existing New Existing New Existing New Existing New or Existing New = A UST System installed after January 11, Existing = A UST Systems installed before January 11, 2008.

If the containment device contains a drain, it must be plugged using a temporary or permanent plug prior to conducting the test.

3 Containment Sump Hydrostatic Test Procedures: 1. Prior to conducting the test, any accumulated trash, debris, or product present must be removed from the containment sump and properly disposed. 2. Test boots and sealed entry fittings must be present and in good condition in order to perform the test. Any missing or damaged fittings must be repaired or replaced before testing. 3. Damaged containment sumps should not be tested, but should instead be noted on the results sheet and reported to the DNREC-TMB in accordance with the reporting requirements listed below. 4. Any equipment present inside the sump should be inspected for product leaks, and repaired before testing. 5. Any liquid sensors present should be removed before testing. 6. Fill the containment sump to the top. It is imperative to entirely fill the sump in order to simulate the hydraulic pressure that the sump and its fittings would be subject to in the event of a product release that entirely filled the sump. 7. Place a rigid straight-edge across the top of the containment sump. The straight edge should be secured in place or its location marked to ensure accurate measurements. Allow the water to settle in the containment sump. Using a measuring device that is accurate to 1/16 th of an inch, measure the distance perpendicular from the straight edge to the top of the water s surface, and record the result. 8. Cover the containment sump, using its lid or an alternative cover, and allow the containment sump to sit undisturbed for one (1) hour for an annual test. Tests for new installations or containment sump replacements must sit undisturbed for 24 hours. 9. After the allotted time frame specified in #8 has elapsed, measure the height of the water level as described above. The test fails if the water level drops 1/8 th of an inch or more. 10. All water must be removed at the completion of the test. It may be re-used for testing purposes or must be properly disposed. Reporting Requirements 1. All reporting must be done on the DNREC-TMB results form that is part of these test procedures. All fields must be completed. 2. All test records must be kept for the lifetime of the UST system. 3. Test failures must be reported to the DNREC-TMB by faxing the results form to within twenty-four (24) hours of the failure. 4. The DNREC-TMB must receive notification of repairs or replacements within thirty (30) days of the test failure. The work must be completed within ninety (90) days of the test failure.

Damaged containment sumps should not be tested, but should instead be noted on the results sheet and reported to the DNREC-TMB in accordance with the reporting requirements listed below. 4.

4 Department of Natural Resources and Environmental Control Tank Management Branch 391 Lukens Drive New Castle, DE (302) (Phone) (302) (Fax) Containment Test Report This form must be used in conjunction with the DNREC-TMB s containment testing procedures document or other manufacturer-approved testing procedures previously approved by the DNREC-TMB. If alternative procedures are used, please attach a procedures document and a letter of approval from the component manufacturer to the results form. Facility Information Owner Information ID # Owner Contact: Facility Name: Company Name: Address: Address: City, State, Zip: City, State, Zip: Phone #: Phone #: Fax #: Fax #: Testing Contractor Information Company: Phone #: Address: Fax #: City, State, Zip: Results Component Manufacturer Capacity Pass/Fail

procedures previously approved by the DNREC-TMB. If alternative procedures are used, please attach a procedures document and a letter of approval from the component manufacturer to the results form.

5 Comments: Certification I certify, under penalty of law, that I have adhered to the proper test procedures and that the information presented here is true, accurate, and complete. Technicians s Signature: Print or Typed Name and Title: Date:

the information presented here is true, accurate, and

Maryland Containment System Testing Protocol. The individual performing the inspection and testing as outlined in this protocol must be either:

Maryland Containment System Testing Protocol. The individual performing the inspection and testing as outlined in this protocol must be either: MARYLAND DEPARTMENT OF THE ENVIRONMENT Oil Control Program, Suite 620, 1800 Washington Blvd., Baltimore MD 21230-1719 4 410-537-3442 410-537-3092 (fax) 1-800-633-6101 http://www.mde.state.md.us Maryland