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Laura FisherUST Leak PreventionCalifornia Water Resources Control Board
What States Should Expect with Secondary Containment TestingNational Tanks ConferenceSeptember 15, 2015
Background
• California has approximately 39,000 UST systems actively storing various types of hazardous substances at over 14,000 facilities.
• Approximately 90% of UST are double‐walled systems (tank and pipe)
• 82 local implementing agencies‐ 200‐225 UST inspectors ‐ Annual UST compliance inspections ‐ Plan check installation/removals, mods‐ Operating permits‐ Enforcement
Secondary ContainmenttTestingRegulations: 2001 ‐ Present• Frequency of Testing
‐ At installation‐ Six months after installation‐ Every three years thereafter
• Performance Standards of Test‐ Demonstrate the system performed at least as well as it did at installation
Secondary ContainmenttTestingRegulations: 2001 ‐ Present• Test method selection procedure
‐ in accordance with the manufacturer’s guidelines
‐ if there are no such guidelines, useindustry codes/engineering standards
‐ if there are no such codes/standardsuse a test method approved by a state registered professional engineer
Secondary ContainmenttTestingRegulations: 2001 ‐ Present
• Qualified Testers‐ State Contractors License‐ ICC Service Technician Certificate‐ Containment Manufacturer Trainingand Certification
• Testing Notification Requirements‐ 48 hour local agency notification
• Testing Submission Requirements‐ Submit testing results to local agency within 30 days
Secondary ContainmenttTestingRegulations: 2001 ‐ Present
• Testing includes tanks, pipe, sumps, and UDC
• Vacuum, pressure, hydrostatic fluid monitoring exemption
• Required at installation, 6 months after installation, and every 3 years thereafter
• Well over 1 million secondary containment tests have occurred in the last 15 years on tanks, sumps, pipe, (and spill buckets)
Secondary Containment Testing Survey
• To properly evaluate the effectiveness of secondary containment testing, the State Water Board UST Program staff conducted a secondary containment performance survey in 2003
• Data collected and evaluated obtained from the first round of secondary containment testing
Secondary Containment Testing Survey
• 50% of UST systems tested had at least one secondary containment component that failed.
• The survey revealed the most common secondary containment failure to be the point at which two components are joined together.
Survey Reported Distribution of Most Common Failure Point and Reason
Reason for Failure• The primary reason cited for failure was accredited to improper installation.
• Material degradation was the second most common reason for failure.
Failure Rate By Component
Tanks – Lowest Failure Rate
Piping – Second Lowest Failure Rate
Sumps & UDC – Highest Failure Rate
05
10152025303540
< 5 %
5-25
%
26-5
0%
51-7
5%
>75%
Unkno
wn
Failure Rate
# of
Par
tici
pant
s
Tanks
Piping
Sumps
UDC
Spill Containment
Failure Rate By Component Material
Secondary Containment Component
Most Common Material Failure
Second Most Common Material Failure
Third Most Common Material Failure
Tank Jacketed Fiberglass Steel Tanks w/CathodicProtection & HDPE Tanks*
Piping Thermoplastic Flexible Piping
Thermoplastic Flexible Piping
HDPE Piping
Sump Fiberglass HDPE Unknown/Other
UDC Coated Steel Fiberglass HDPE
Be Advised
• Installation of test boots• Repositioning test boots• Tightening clamps on test boots • Plugging test ports into test boots• Temporarily removing or disabling
monitoring sensors• Removing debris • Cleaning‐out sumps to reduce the
amount of contaminated liquid generated
• Increased Repairs/Construction
Management of Hydrostatic Test Fluids ‐Classification
• Cleaning of spill containment prior to testing
• Test fluid will typically not become hazardous waste
• Recommended to use new test fluid
Management of Hydrostatic Test Fluids –Reuse
• Contaminants build up in the test fluid
• Reused test fluid is not considered to be waste pursuant to U.S. EPA's "continued use" policy
• Hazardous waste generator shall determine if the test fluid is a hazardous waste
Management of Hydrostatic Test Fluids –Leakage
• Reused test fluid leaks to the environment during a test
• Address the release
Management of Hydrostatic Test Fluids –Disposal/Transportation
• Reused test fluid is hazardous waste
• Managed in accordance with all applicable requirement
• Uniform Hazardous Waste Manifest
• Use a registered hazardous waste transporter
• Dispose at a permitted hazardous waste facility or to another location authorized to accept the waste
Test Boots and PortsAcceptable Positions
Test boots located in sumps (other than UDCs) must either:
• Pulled back and off; or • Test boot’s port oriented in a 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.
Test Boots and PortsAcceptable Positions
Connected UDCs, both test boots must either: • Pulled back and off; or • Test boot’s port oriented in a 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.
Test Boots and PortsAcceptable Positions
Stand alone UDCs:• Position of test boots and/or reducer
fittings in the UDC (on or off) does not cause a significant delay in leak detection or substantially increase the risk of a release to the environment but does incur an unnecessary cost to compliance.
Considerations for Upcoming Rulemaking
• Licensing/Certifications• Notifications/testing submittals• Sensor relocation• Boot and Fitting Port Position• How to handle system modifications
• Pre‐Testing
Laura S FisherCalifornia Underground Storage Tank Programlaura.fisher@waterboards.ca.gov
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