Secondary Containment TestingSecondary Containment Testing(Sumps, Buckets, Pans, Piping)(Sumps, Buckets, Pans, Piping) ‏‏

2020thth Annual NationalAnnual NationalStorage Tanks ConferenceStorage Tanks Conference

Atlanta, GAAtlanta, GAMarch 17, 2008March 17, 2008

Presented by:Presented by:Edward Kubinsky Jr.Edward Kubinsky Jr.

Special Projects ManagerSpecial Projects ManagerCrompco, LLCCrompco, LLC

ed.kubinsky@crompco.comed.kubinsky@crompco.com(800) 646(800) 646--31613161

What Types of Containment What Types of Containment Systems are being tested?Systems are being tested?

Spill BucketsSpill Buckets

Tank SumpsTank Sumps

Dispenser Dispenser SumpsSumps

Piping Piping SecondariesSecondaries

Who is Who is RequiringRequiring these systems to these systems to be tested?be tested?

The following states in CrompcoThe following states in Crompco’’s current coverage area are requiring s current coverage area are requiring containment testing:containment testing:

AL (spill buckets annuallyAL (spill buckets annually--new requirement)new requirement) ‏‏DE (spill buckets annually, new sumps & dispenser pans every 3 yDE (spill buckets annually, new sumps & dispenser pans every 3 years ears [except if DW w/ IM] and existing sumps & pans every 3 years if [except if DW w/ IM] and existing sumps & pans every 3 years if used for used for release detection [except if DW w/ IM] release detection [except if DW w/ IM] -- new requirement)new requirement) ‏‏FL (coming this year?)FL (coming this year?) ‏‏MD (spill buckets annually, sumps & dispenser pans every 5 yearsMD (spill buckets annually, sumps & dispenser pans every 5 years--required as required as of 3 years ago)of 3 years ago) ‏‏NH (spill buckets, sumps & dispenser pans at installation only)NH (spill buckets, sumps & dispenser pans at installation only) ‏‏OH (spill buckets, sumps & dispenser pans every 3 years as of 12OH (spill buckets, sumps & dispenser pans every 3 years as of 12/05)/05) ‏‏PA (spill buckets, sumps & dispenser pans at installation only)PA (spill buckets, sumps & dispenser pans at installation only) ‏‏Important Note: Some owner/operators have recognized problems aImportant Note: Some owner/operators have recognized problems associated ssociated with containment systems and are conducting periodic containmentwith containment systems and are conducting periodic containment testing testing and inspections proactively in areas where it is not required toand inspections proactively in areas where it is not required to test in order to test in order to prevent problemsprevent problems

Problems associated with Problems associated with containment testing from the testers containment testing from the testers

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

Crompco Test DataCrompco Test Data

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

1/23/081/23/08

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

What weWhat we’’re findingre finding……Spill Buckets:Spill Buckets:

36,830 tests performed36,830 tests performed31,853 passing (86.5%)31,853 passing (86.5%) ‏‏4,977 failing (13.5%)4,977 failing (13.5%) ‏‏

Comments on Spill BucketsComments on Spill Buckets

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

What weWhat we’’re findingre finding……(cont.)(cont.) ‏‏Tank SumpsTank Sumps

10,686 tests performed10,686 tests performed8,339 passing (78%)8,339 passing (78%) ‏‏2,347 failing (22%)2,347 failing (22%) ‏‏

What weWhat we’’re findingre finding……(cont.)(cont.) ‏‏Dispenser SumpsDispenser Sumps

13,702 tests performed13,702 tests performed11,169 passing (81.5%)11,169 passing (81.5%) ‏‏2,347 failing (18.5%)2,347 failing (18.5%) ‏‏

What weWhat we’’re findingre finding……(cont.)(cont.) ‏‏Piping Secondaries Piping Secondaries

(line interstitial (line interstitial spaces)spaces) ‏‏

6,453 tests performed6,453 tests performed5,386 passing (83.5%)5,386 passing (83.5%) ‏‏1,067 failing (16.5%)1,067 failing (16.5%) ‏‏

Comments for DiscussionComments for Discussion

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

THANK YOU!THANK YOU!Edward Kubinsky Jr.Edward Kubinsky Jr.

Special Projects ManagerSpecial Projects ManagerCrompco, LLCCrompco, LLC800800--646646--31613161

ed.kubinsky@crompco.comed.kubinsky@crompco.comwww.crompco.comwww.crompco.com