Sump Integrity Testing
Questions Answered: Containment Sump Integrity Testing in Fueling Facilities
For the first time in more than 25 years, the EPA has revised its underground storage tank (UST) regulations. The updated regulations included multiple new regulatory requirements including, among others, mandatory 30-Day walkthrough inspections and required Class A, B and C Operator Training. One of the most substantive changes in the area of operational and maintenance requirements is related to Spill Prevention and Containment Sump Testing or more commonly known as ‘Sump Integrity Testing’. The purpose of which is designed to reduce the incidence and impact of the more than 6,000 releases discovered annually from USTs. The following is a guide to help shed light to the requirements and the expectations for facility owners.
According to EPA guidelines, by October 2018 it will be mandatory that all sumps undergo an integrity test that ensures sumps are water tight. Containment sumps include under dispenser containment, STP sumps and fill sumps. As a liquid tight structure, sumps are designed to temporarily contain leaks or spills. Containment sumps often serve as the leak detection monitoring location for double-walled piping systems. Leakage from the primary piping typically flows by gravity inside the secondary piping to the sump, where it can be easily observed or detected by a sensor. The containment sump is a critical component in preventing spills and in this case must be designed to prevent any spillage into the environment.
Every 3 years it will be mandatory to all containment sumps undergo an integrity test, ensuring that sumps are water tight
Many questions have surged in the wake of the new requirements. Who is qualified to perform the test? What is the process for testing sumps and probably most important, what happens if water leaks into the soil through one of the entry boot fittings or via another un-tight source? The concern of whether or not the sumps will hold water for any significant amount of time is a question of great debate and one that strikes fear into the heart of many facility owner/operators.
The process for testing containment sumps as defined by the PEI in their Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities lays out the guidelines for performing a hydro-static test on the sump. The purpose of this test is to determine any leaking points from the sump by filling it with water and observing over a period of time.
The Hydrostatic Testing Process:
- Ensure all pipe penetrations are free from bedding or back fill material or any other obstruction
- Fill the sump with fresh water to the highest point
- Mark the water level inside the sump with a marker pen or chinagraph (wax) pencil
- Examine the pipe entry seals for signs of leaking water
- Leave water in sump for 1 hour
- Check water level has not dropped — to properly finish testing
The hydro-static test for Sump Integrity testing, although an efficient method of determining leaks, presents a major concern to owner/operators and testing providers: if a leak occurs it must be reported withing two hours to the DEC and subsequent action must be taken to correct the issue. This is a great concern to all parties involved and one that suggests the definition of a clear set of guidelines before beginning the test must be put in place. For many this means all repairs on entry boot fittings and leaky conduit should be made on the sump prior to filling with water. In this way the possibility of a leak occuring will be greatly diminished.
For many, containment sump testing represents unchartered territory. As we approach the 2018 deadline and await the DEC’s final ruling on how tests should be performed many questions will continue to arise. I hope that this article could shed some light on some of the background of containment sump testing. As always we are here to help and look forward to your feedback
Your Colleague and Friend,
Rob Henrich, COO Henrich Equipment