2018 EPA Rule Requirements
EPA testing requirements will be
enforced as of October 13th, 2018
2018 EPA Rule Requirements
EPA testing requirements will be enforced as of October 13th, 2018!
The following is an opportune time to reach out to our loyal customers with greater details on what this EPA requirement means, and the process involved to perform this testing.
The regulations define that any facility built after Jan. 2009 will be required to have their sites containment sump and spill/fill buckets tested. Facilities built before the Jan. 2009 date will need their spill/fill buckets tested, and their containment sumps tested only if their site is registered as “interstitial line leak” monitoring. Because the state’s letter defines “whom” needs to complete this testing to meet the EPA requirement, I will focus on what needs to be done to perform the testing. As always, if you have any questions about your specific site’s status regarding this requirement, please give us a call.
The testing requirements are to determine if the containment sumps and spill/fill buckets are in good condition and have the ability to hold fuel product should a spill or leak occur. There are two safe methods to test this equipment: through a vacuum or hydrostatic method.
We will focus on the hydrostatic method as it works best for the dispenser sump testing. To perform the required testing, we follow the Petroleum Equipment Institute (PEI) RP 1200 manual. This is the “recommended practice” procedure provided by the PEI. The testing process requires that the sumps and spill buckets hold water for not less than a one-hour period and the level of the water does not drop more than 1/8” during that time duration.
To better explain the testing process lets use a (4) dispenser, (2) tank site as the example. This example site would have (8) total devices that require testing, namely:
- 4 dispenser sumps
- 2 submersible tank sumps
- 2 spill/fill buckets (1 for each tank)
The PEI RP 1200 practice to test these (8) devices would be as follows:
- We are assuming that all (8) devices are free of product, sludge, debris, cracks, and all piping and conduit sealing boots are in good operational condition.
- The testing requirement is to fill the containment sumps with water to a level 4 inches above any permeation (product piping or electrical conduits) into the sump.
- The water level must then be documented at that level (a yardstick or other measuring device). We plan to use a time/date stamped photograph to document this.
- The water level then must remain at that level for at least a 1-hour period and not drop more than 1/8 inch from its beginning level. At the end of the 1-hour period we will take another time/date stamped photograph.
- We would then move onto the next device requiring testing. *(multiple devices can be tested in parallel succession for efficiency sake)
The RP1200 testing form will be utilized to document this testing for you as proof should the EPA perform an inspection of your facility to confirm its completion.
Once the testing process is completed the water used in the testing process will need to be properly disposed of per DNR standards for water containing hydrocarbons. Even though the sumps appear clean, there are residual petroleum hydrocarbons present from past leaks, filter changes etc. There are (3) potential methods for proper disposal of this testing water:
- Barrel it and utilize a contracted disposal processing
- Your car wash oil/water separator (with local authority permission)
- A portable carbon filtration unit that we have available for a fee
As I stated earlier, the above example assumes that all devices are in good functional working order. Unfortunately, we are all aware that the petroleum product and more importantly it’s vapors, the effects of the freeze-thaw cycle and mother nature herself can cause great wear and tear on all these devices. The sump sealing boots will be the most important item to verify for integrity. Our company alone has used many different sumps boots over the years as well as different types used by other companies as well.
Given those facts, we feel a more efficient process will be to have our company perform an initial site inspection of the devices requiring testing. That would allow us to confirm if the sump boots and spill/fill bucket drains are in satisfactory condition to even consider the testing process. If not, the correct boots can then be ordered and properly installed before the testing process is performed.
**(NPS is working on a special schedule to focus on these sump inspections solely with the intent to bundle multiple sites if/when possible to save you some travel fees).
As we have for the past 46 years, Northwest Petroleum Service is here to answer your questions and provide you the services and products you need to run your business.
Northwest Petroleum Service, Inc.