2017 NISTM St. Louis, MO

Release Detection Equipment Testing – 101

Founded in 1988, Tanknology has grown to become

the largest forecourt compliance testing and

inspection services company in the World.

Our fleet of 160 vehicles provides service in all 50

states domestically, and we have a presence in more

than 30 countries, 6 continents through

international licensees.

We hold 22 patents covering our test equipment

and various leak detection methodologies.

Headquarters in Austin, TX

8 Strategically Located Regional Offices:

• Southern California• Northern California• Austin• Minneapolis• Chicago• Columbus, OH• Atlanta• Philadelphia

Our regional operatingstructure empowers us to

provide the bestcustomer experience.

National Reach, Local Focus

Tanknology’s National Coverage

and regional operating structure

enables us to provide consistent

high quality service to ALL

customers, ranging from single site

operators to “the majors”

For purposes today this means we are often the first to see:

- New Equipment

- New Test Procedures

- First to go through the learning curve

- Advisory role as specified in new markets

40 CFR 280, the regulated UST community as of October 13, 2015 is required to…..

…..phase in new inspections and testing starting as early as October 13, 2018 and ending ????

Must follow one of the following criteria:

-Requirements developed by

manufacturer*

-Code of practice developed by a

nationally recognized association

or independent testing laboratory ---

PEI RP 1200 specified in EPA regulation

-Requirements determined by implementing

agency to be no less protective….

• Overfill Protection – test 1x every 3 years

• Spill Buckets – test 1x every 3 years, if not double

walled with periodic(not continuous) monitoring

• Containment Sumps - test 1x every 3 years, if not

double walled with periodic(not continuous)

monitoring

• Tank Monitoring Devices – must be tested annually,

including battery backup(if present), elld’s, hand held

sampling equipment

• Overfill Drop Tubes

• Ball Float Valves • 90%

• 30 minute

• External High Level Alarm • Audible

• Visual

• PEI RP 1200

– Remove drop tube

– Visually inspect

– Manually move float mechanism

Adapter removed/jack

screw kit

• Remove the ball float• Visually inspect the

ball float and cage • Check ball for holes

and cracks • Check vent orifice /

breather hole

PEI RP 1200

Length dependent on 1/8” v. 1/16” breather hole

-Dip tank and compare product level (quiet time)-Verify Overfill alarm is set to 90%(use tank chart)-Verify external horn/light work-Remove probe – simulate Delivery -Stop moving product float when alarm sounds -Record data and determine P/F

Alarm needs to be outside and visible from the tank pad(left), not the console in the back office(right)

• Tank Diameter – chart, measured, other(atg)• Tank Deflection • Tank Tilt • Other overfill device(s)• Manipulation of device• Carpenter error – standard deviation • Vapor tight(ball float)

• Confirm cap and adapter, as well as drain valve, are liquid tight, make repairs as needed

• Optional - use plumbers plug to isolate below drain• Fill spill bucket to within 1.5” of the top of the

bucket before the initial reading is taken• One hour test – drop less than 1/8”

Single Walled

BucketDouble Walled Bucket

• Preparation – clean, inspect/visual failures, secure test boots, remove sensors(unless??)

• Add test water to 4” above highest penetration or sidewall seam, whichever is higher

• Allow 15 minutes to settle

• One hour test, less than 1/8” drop = P

Dispenser Boots – Inspections

• CA Guidance Letter March 1, 2013 - To provide for the detection of a

leak at the “earliest possible opportunity,” test boots and/or reducer

fittings in the UDC of piping runs that are monitored for leaks by use of

sloping the piping back to a monitored sump may stay on in any

position. Piping runs that connect one UDC to another UDC must have

the test boots and/or reducer fittings located in both UDCs either: 1)

pulled back and off; or 2) oriented so that the test boot’s and/or reducer

fitting’s port is in the downward position (located between the three and

nine o’clock positions), uncapped, and with the valve stem capable of

allowing for drainage so that a leak from the product piping can be

detected ---

http://www.swrcb.ca.gov/ust/tech_notices/boots_030113.pdf

A liquid level sensor is mounted at the lowest point

in the sump and a periodic test is performed by

adding liquid to a point that will ensure activation of

the sensor*; and

The pump automatically shuts off when product

activates the sensor, or

The dispenser automatically shuts off when product

activates the sensor, and the facility is always

staffed when the pumps are operational.

• In Tank Probes(ATG)

– Compare existing fuel/water to dipped

– Remove and inspect, floats move freely

– Simulate all low and high level product and water alarms

– Record alarm level of float(s) corresponds with tank gauge programming

• Peripheral Sensors

– Remove sensor from lowest point of containment

– Fill test container with proper fluid, water of fuel

– Place sensor in liquid and verify proper alarm condition

– Remove, drain, and properly clean sensor

– Return sensor to the proper location

• Questions

– Lowest point of containment to detect a leak at the earliest time

– Certification P/F – when left in alarm

• References

– Veeder Root Manual 577013-814 – Rev J

Utilize best practices and common sense

• Equipment is present to prevent significant issues

Maintenance Plan – scheduled and response based

• Properly trained technicians addressing the issue

• Central theme to compliance is dealing with issues as they occur, not waiting until non-performance

Brian Derge

Tanknology

bderge@tanknology.com

512-415-0751