Containment sumps and spill buckets are components that are part of a fueling station’s underground storage tank system. They are designed to temporarily contain leaks or spills that may occur. Since their primary function is to prevent leaks from escaping the fueling system, the U.S Environmental Protection Agency (EPA) requires that these components be tested regularly to ensure they are liquid-tight. Here are 5 things C-store operators need to know about liquid-tight testing.
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1. Different deadlines to complete the testing apply, depending on when the containment equipment was installed and what state the station is located in. For equipment installed prior to Oct. 13, 2015, and that is located in states that follow the EPA’s 2015 Underground Storage Tank Regulations, the equipment needs to be tested every three years, with the first tests due in 2021. Spill prevention equipment and containment sumps installed after Oct. 13, 2015, must be tested for liquid tightness at installation and then once every three years. Some states may have different compliance deadlines. Reference Source’s State-by-State Guide to UST Regulations to learn about your state’s requirements.
2. If the spill prevention equipment and containment sumps that are used for piping interstitial monitoring are double-walled, the EPA requires the integrity of both walls to be monitored at least as frequently as its walkthrough inspection requirements. This is typically every 30 days for spill buckets but it may be longer if the facility receives infrequent deliveries, and annually for containment sumps. If owners and operators discontinue this periodic monitoring, they have 30 days to conduct vacuum, pressure, or liquid testing.
3. If the spill prevention equipment and containment sumps that are used for piping interstitial monitoring are not double-walled, then they need to be tested once every three years by using either vacuum, pressure, or liquid testing. This testing needs to meet one of the following criteria:
- Testing requirements were developed by the manufacturer
- The testing meets a code of practice such as the Petroleum Equipment Institute’s RP1200
- The testing requirements were determined by the implementing agency and are no less protective than those developed by the manufacturer or in a code of practice
Learn more about the EPA’s spill prevention and containment sump testing deadlines and requirements on the EPA’s Underground Storage Tank’s Operating And Maintaining UST Systems — 2015 Requirements webpage.
4. ASTM International’s ASTM E3225-20 does not meet the EPA’s testing requirements. ASTM recently released a new standard for spill bucket and sump testing (ASTM E3225-20). However, the EPA announced that ASTM’s procedures, which are visual in nature, do not meet its regulatory requirements for spill prevention and sump testing. A visual inspection may alert operators to potential problems that need to be addressed, but it does not constitute an integrity test that will meet compliance requirements. Learn more in this Q&A from the EPA.
5. Follow the EPA’s Pre-testing Checklist to get a jump on correcting problems. In an addendum issued by the EPA in 2018 about Low Liquid Level UST Containment Sump Testing Procedures, the agency offers a pre-testing checklist that, when followed, will provide an early indication of problems that will likely cause a test failure. If issues are discovered during the pre-testing checklist, the agency recommends the problems be corrected prior to compliance testing.
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