Secondary Containment Testing Sumps, Buckets, Pans, Piping

1
Secondary Containment Testing (Sumps, Buckets,
Pans, Piping)?

• 20th Annual National
• Storage Tanks Conference
• Atlanta, GA
• March 17, 2008
• Presented by
• Edward Kubinsky Jr.
• Special Projects Manager
• Crompco, LLC
• ed.kubinsky_at_crompco.com
• [phone]

2
What Types of Containment Systems are being
tested?

• Spill Buckets
• Tank Sumps
• Dispenser Sumps
• Piping Secondaries

3
Who is Requiring these systems to be tested?

• The following states in Crompcos current
  coverage area are requiring containment testing
• AL (spill buckets annually-new requirement)?
• DE (spill buckets annually, new sumps dispenser
  pans every 3 years except if DW w/ IM and
  existing sumps pans every 3 years if used for
  release detection except if DW w/ IM - new
  requirement)?
• FL (coming this year?)?
• MD (spill buckets annually, sumps dispenser
  pans every 5 years-required as of 3 years ago)?
• NH (spill buckets, sumps dispenser pans at
  installation only)?
• OH (spill buckets, sumps dispenser pans every 3
  years as of 12/05)?
• PA (spill buckets, sumps dispenser pans at
  installation only)?
• Important Note Some owner/operators have
  recognized problems associated with containment
  systems and are conducting periodic containment
  testing and inspections proactively in areas
  where it is not required to test in order to
  prevent problems

4
Problems associated with containment testing from
the testers perspective

• No manufacturer published recommended procedures
  or not readily available
• No state guidance to contractors on recommended
  procedures so there are many variations of tests
  being performed (except MD who has issued a
  containment testing protocol that is required to
  be followed and AL has published guidance and
  developed a form)?

5
Crompco Test Data

• Data being shared is inclusive of tests performed
  between 7/1/03 through 1/23/08

6
Explanation of Results

• Prior to conducting sump and dispenser pan
  containment testing, technicians will thoroughly
  inspect the containment device, tighten boot
  clamps and attempt to repair any items that may
  cause a failure.
• When conducting spill bucket testing, drop tubes
  will be removed and the tank riser will be sealed
  below the drain valve to prevent test water (if
  hydrostatic testing) from entering the tank and
  also prevent a failed test due to a
  non-functioning drain valve because the drain
  valve leaking into the tank does not compromise
  the integrity of the bucket.
• When conducting secondary piping containment
  testing, all entry boots are inspected and
  tightened at the STP and dispenser ends

7
What were finding

• Spill Buckets
• 36,830 tests performed
• 31,853 passing (86.5)?
• 4,977 failing (13.5)?

8
Comments on Spill Buckets

• Spill bucket data is inclusive of all tests
  performed. Several of Crompco's major customers
  have undergone large voluntary spill bucket
  replacement programs which included the
  installation and testing of a couple thousand new
  spill buckets which should be taken into
  consideration when viewing this data. We feel
  that without these proactive programs, the
  testing data would be significantly different
  indicating a much larger percentage of failing
  spill bucket tests.

9
What were finding(cont.)?

• Tank Sumps
• 10,686 tests performed
• 8,339 passing (78)?
• 2,347 failing (22)?

10
What were finding(cont.)?

• Dispenser Sumps
• 13,702 tests performed
• 11,169 passing (81.5)?
• 2,347 failing (18.5)?

11
What were finding(cont.)?

• Piping Secondaries (line interstitial spaces)?
• 6,453 tests performed
• 5,386 passing (83.5)?
• 1,067 failing (16.5)?

12
Comments for Discussion

• Are we confident that the containment devices out
  there are being maintained and will contain a
  release when they occur?
• What type of periodic testing and/or maintenance
  schedule would you recommend for containments (if
  any)?
• How long is this equipment designed to last
  (forever)?
• What can we do better?

13
THANK YOU!

• Edward Kubinsky Jr.
• Special Projects Manager
• Crompco, LLC
• 800-646-3161
• ed.kubinsky_at_crompco.com
• www.crompco.com