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– Interstitial Integrit y Testing 1 Task Order No. 1010 – General Technical And Programmatic Support In Implementing The Energy Policy Act Of 2005 Task 1010 - 04

– Technical Research/Analy sis And Summarize Information Subject 4

– Secondary

Containment Subtask SC - 05

– States’ Periodic Intersti tial Integrity Testing Requirements E 2 In c. researched all 50 states and the District of Columbia to identify : which states require periodic interstitial integrit y testing (also known as secondary

containment testing), the options for meeting those requir ements, and the costs of those options. E 2 In c. used state Web sites, online statutes and regulations, Internet searches, and phone calls to several states. Periodic interstitia l integrity testing recurs at regular intervals; it does not include testing during installation or episodic testing (for example, testing that is required if a leak is suspected). At the direction of OUST’s subject matter expert for secondary containment, Paul Miller, E 2 In c. did not investigate state requirements for episodic interstitial integrity testing or interstitial integrit y testing during installation. In addition, in general, E 2 Inc. did not investigate states where periodic interstitial integrity testing is one of several options because, b y presentin g options, these s tates are not requiring interstitial integrit y testing. For all of the states that require periodic interstitial integrity t esting, Table 1 presents information about the requirements and options for meeting the requirements. There are three general meth ods of interstitial integrity testing: vacuum, pressure, and hy drostatic. All three methods can be conducted either continuously or periodicall y. The vacuum method involves drawing a vacuum on the interstitial space and monitoring for a decrease in the v acuum. The pressure method involves creating a very slight pressure in the interstitial space and monitoring for a decrease in the pressure. The h ydrostatic method involves filling the interstitial space with a liquid and monitoring for a change in the l evel of liquid. The continuous hy drostatic method, which is used only for tanks (primarily

fiberglass tanks), involves filling the tank’s interstice with liquid (for example, brine); the liquid level is then automatically monitored for an increase or decr ease. The periodic hy drostatic method is performed by filling the interstice with liquid and then, after some time has passe d, checking for a drop in the liquid’s level; the time elapsed can be 24 hours for a visual determination or 15 - 30 minutes using a more advanced technology

that can discriminate smaller drops in liquid level than can the human ey e (for example, Tanknology uses “the patented VPLT precision test sy stem” to test containment sumps and dispenser pans “in as little as 15 minutes”). E 2 In c . interviewed two Tanknology employ ees at two different locations. Tanknology is a company

that performs periodic secondary containment testing, among other tank services. Both employ ees interviewed stated that the predominant periodic secondary containm ent testing methods used by their Tanknology

locations are: vacuum testing for tanks, pressure testing for piping, andJuly

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– Interstitial Integrit y Testing 2 hy drostatic testing for tank sumps and dispenser sumps. According to the company ’s secondary containment brochures, these ar e the method s used at all Tanknology locations, both in California and elsewhere. 1 E 2 In c. obtained costs for periodic secondary containment testing from the two Tanknology locations; these are recurring costs incurred every

time the test is performed. E 2 Inc. obta ined from a Xerxes Corporation representative the cost to equip a double - walled fiberglass tank with brine for continuous h ydrostatic monitoring; this is a one - time cost incurred at the UST’s purchase

– there are no additional, recurring costs. The costs are presented in Table 2. Table 1: States’ Periodic Interstitial Integrity Testing Requirements And Options State Does The State Require Periodic Interstitial Integrity Testing? Options CA New USTs (installed after 1983, or farm fuel USTs installed aft er 1986 (§2611)): 1 Secondary

containment must be tested upon installation, 6 months after installation, and every 36 months thereafter (s ys tems with continuous monitoring are exempt from periodic testing) (§2637); annual tightness testing required for unde rground pressurized piping and under - dispenser piping if certain conditions are not met (§2636(f)). Interstitial spaces of tanks and piping of USTs installed on or after July 1, 2004 must be continuously

monitored using vacuum, pressure, or interstitial li quid level measurements (HSC §25290.1(e)) 2 Pressure, vacuum, or h yd rostatic

FL UST sy stems installed on or after July 13, 1998 (§62 - 761.200(70)) that have closed interstices must have the tank’s and piping’s interstices tested for a breach of integrity at installation and every

5 y ears, unless the testing is continuous (breach of integrity testing not required for piping sumps and dispenser liners) (§62 - 761.640(3)(a)(2)) 3 Continuous hydrostatic sy stem approved by DEP, continuous vacuum sy stem approved by D EP, liquid tightness test in accordance with manufacturer’s instructions, or other approved method (§62 - 761.640(3)(a)(2)) MD Only

if the owner is claiming secondary containment as his release detection method, in which case tank and piping must be tested annually ; 4 there are also sump testing requirements that could be considered interstitial testing (twice per ye ar for high - risk ground water areas, annually for rest of state) Hy drostatic (brine), vacuum, pressure

1 http://www.tanknology.com/pdf/SecCont%20NON%20California.pdf , http://www.tanknology.com/pdf/SecondaryContainment.pdfJuly

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– Interstitial Integrit y Testing 3 State Does The State Require Periodic Interstitial Integrity Testing? Options OH Double - walled underground piping in ha zardous substance UST s ys tems and in sensitive areas must have annual interstitial tightness testing (1301:7 - 9 - 08(F)(5)); 5 double - walled underground pressure piping must have monthly or annual interstitial tightness testing (1301:7 - 9 - 08(F)(4)(b)); double - w alled underground suction piping that does not meet certain requirements must have interstitial tightness testing every 36 months (1301:7 - 9 - 08(F)(4)(c)) Follow manufacturer’s requirements

RI Existing double - walled UST sy stems must have interstitial tightn ess testing (for tank only) 6 beginning 20 ye ars after installation, and every 2 y ears after that (§8.08(A)(3)) 7 Vacuum, pressure, brine level 8 UT When a sump sensor is used as a leak detector, the secondary containment sump must be tested for tightness an nually (R311 - 203.5(c)); 9 no operators have chosen this option ye t because it is less expensive to use line leak detectors 10 Follow manufacturer’s guidelines or other method approved b y the State 11 (no methods have been approved yet) 12 Table 2: Costs For S elected Interstitial Integrit y Tests

Method Cost Periodic Tests (recurring costs) Vacuum (for tanks) $110

–200 per tank Pressure (for piping) $95

– 110 per line (3

– 8 lines per facility is t ypical) Hy drostatic (for sumps) Tank sump $150 per sump Dispenser sump $150 per sump Spill bucket $95 each Continuous Monitoring (one - time costs)July

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– Interstitial Integrit y Testing 4 Additional cost to equip double - walled UST with brine and reservoir for h ydrostatic monitoring 5,000 gallon UST $1,300 10,000 gallon UST $1,800 12,000 gallon UST $2,021July

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– Interstitial Integrit y Testing 5 Interviews Conducted: States
 Kevin Gillen of Rhode Island’s Department of Environmental Management  Herb Meade of Mary land’s Department of the Environment  Tom Walter of Mary land’s Department of the Environment  Dav id Wilson of Utah’s Department of Environmental Quality Interstitial Testers
 Jerry Belloli of Tanknology

in Sacramento, California  Dave Grenier of Tanknology in Cherry

Hill, New Jersey Tank Manufacturers
 Rod Walsh, representative for Xerxes Corporation  Jim Evans of Modern Welding Compan y of Georgia, Inc. All interviews were conducted in June 2006.July

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– Interstitial Integrit y Testing 6 Appendix A: Selected Relevant Legal Language 

### California www.calregs.com BARCLAYS OFFICIAL CALIFORNIA CODE OF RE GULAT IONS

TI TL E 23. WATERS DI VI SI ON 3. STATE WATER RESOURCES CONTROL BOARD AND REGIONAL WATER QUALITY CONTROLBOARDS CHAPTER 16. UNDERGROUND TANK REGULATIONS

ARTI CL E 1. DEFINITION OF TERMS This database is current through 04/21/06, Register 2006, No. 16. 23 CCR s 2611 Cal. Admin. Code tit. 23, s 2611 s 2611. Additional Definitions.

... "Existing underground storage tank" means an underground storage tank installed prior to January 1, 1984. The term also includes an underground storage tank installed before January 1, 1987 and which is located on a farm, has a capacit y greater than 1,100 gallons, and stores motor vehicle fuel used primaril y for agricultural purposes and not for resale.

... "New underground storage tank" means an underground storage tank which is not an existing underground storage tank. 23 CCR s 2636 Cal. Admin. Code tit. 23, s 2636 s 2636. Design, Construction, Installation, Testing, and Monitoring Requirements for Piping.

... (f) Underground piping with secondary containment, including under - dispenser piping with secondary

containment, shall be equipped and monitored with monitoring s ys tems as follows: (1) All secondary

containment, including under - dispenser containment, and under dispenser spill control or containment sy stems shall be equipp ed with a continuous monitoring sy stem that either activates an audible and visual alarm or stops the flow of product at the dispenser when it detects a leak. (2) Automatic line leak detectors shall be installed on underground pressurized piping and shall be capable of detecting a 3 - gallon per hour leak rate at 10 psi within 1 hour withJuly

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– Interstitial Integrit y Testing 7 a probability

of detection of at least 95 percent and a probability of false alarm no greater than 5 percent, and shall restrict or shut off the flow of product through the piping when a leak is detected. (3) Until November 9, 2004, other monitoring methods may be used in lieu of the requirement in subdivision (2) if it is demonstrated to the satisfaction of the local agency that the alternate method is as effective as the methods otherwise required by this section. Continuous monitoring sy stems as described in subdivision (1), which shut down the pump in addition to either activating the audible and visual alarm or stopping the flow of product at the dispenser, satisfy the automatic line leak detector requirement of subdivision (2). (4) Monitoring shall be conducted on all underground pressurized piping with secondary containment at least annually at a pressure designated by the equipment manufacturer, provided that the method is capable of detecting a minimum release equivalent to 0.1 gallon per hour defined at 150 percent of the normal operating pressure of the product piping s ys tem at the test pressure with at least a 95 percent probability of detection and not more than a 5 percent probability of false alarm. (5) Continuous monitoring s ys tems as described in subdivision (f)(1) satisfy the annual tightness testing requirement of subdivision (f)(4) if both of the following conditions are met: (A) The monitoring s ys tem shuts down the pump or stops the flow of product at the dispenser when a leak is detected in the under - dispenser containment. (B) The monitoring s ys tem for all product piping other than that contained in the under dispenser containment is fail safe, and shuts down the pump when a leak is detected. (6) For emergency

generator tank s ys tems, continuous monitoring sy stems as described in subdivision (1), which activate an audible and visual alarm in the event of a leak or a malfunction of the monitoring s ys tem satisfy the automatic line leak detector requirement of subdivision (2), provided that the monitoring s ystem is checked at least daily by either remote electronic access or on - site visual inspections. A log of daily checks shall be available for local agen cy review upon request. 23 CCR s 2637 Cal. Admin. Code tit. 23, s 2637 s 2637. Secondary Containment Testing. (a) Secondary

containment sy stems installed on or after January 1, 2001 shall be tested upon installation, 6 months after installation, and eve ry 36 months thereafter. Secondary containment sy stems installed prior to January 1, 2001 shall be tested by January 1, 2003 and every 36 months thereafter.July

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– Interstitial Integrit y Testing 8 (b) By December 31, 2002, the owner or operator of any secondary

containment sy stem that the owner or operator determines cannot be tested in accordance with this section shall replace the secondary containment s ys tem with a sy stem that can be tested in accordance with this section. As an alternative, the owner or operator may submit a proposal and wor

kplan for enhanced leak detection to the local agency in accordance with subdivisions 2644.1(a)(1), (2), (4), and (5) b y July 1, 2002; complete the program of enhanced leak detection by December 31, 2002; and replace the secondary containment sy stem with a sy stem that can be tested in accordance with this section by July 1, 2005. The local agency

shall review the proposed program of enhanced leak detection within 45 day s of submittal or re - submittal. (c) Periodic testing of secondary containment s ys tems sh all be conducted using a test procedure that demonstrates that the sy stem performs at least as well as it did upon installation. For example, if the secondary containment sy stem was tested upon installation by

using a test method that applied a pressure of 5 psi, then the periodic test must be conducted using a method that tests the system at an equivalent pressure. These tests shall be performed in accordance with manufacturer's guidelines or standards. If there are no manufacturer's guidelines or standard s, secondary containment sy stems must be tested using an applicable method specified in an industry code or engineering standard. If there are no applicable manufacturers guidelines, industry codes, or engineering standards a test method approved b y a stat e registered professional engineer shall be used. (d) Secondary

containment testing shall be performed by either a service technician or a licensed tank tester, both of which must meet the requirements of section 2715, subdivision (i). (e) Underground st orage tank owners and operators shall submit a copy of the test report to the local agency

within 30 day s of the completion of the test. (f) Owners and operators of underground storage tanks must notify the local agency

at least 48 hours prior to conducti ng the test, unless this notification requirement is waived by the local agency . (g) Secondary

containment sy stems where the continuous monitoring automatically monitors both primary

and secondary

containment, such as s ys tems that are hy drostatically

moni tored or under constant vacuum, are exempt from periodic secondary containment testing. http://www.waterboards.ca.gov/ust/regulatory /ab2481_status.html 25290.1.

... (e) The interstitial space of the underground storage tank shall be maintained under constant vacuum or pressure such that a breach in the primary or secondary containment is detected before the liquid - or vapor - phase of the hazardous substance stored in theJuly

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– Interstitial Integrit y Testing 9 underground storage tank is released into the environment. The use of interstitial liquid level measurement methods satisfies the requirements of this subdivision. http://www .waterboards.ca.gov/ust/regulatory /ab1702_enacted.html The Governor signed Assembly Bill (AB) 1702 (Statutes 2003, Chapter 42) into law on July 7, 2003. As an urgency

bill, the requirements of AB 1702 are effective immediately . Among other things, AB 17 02 extends the July 1, 2003 deadline for TWO requirements of AB 2481 (Statutes 2002, Chapter 999). Specifically , AB 1702 extended the deadline until July 1, 2004 for: (1) the continuous monitoring of the interstitial spaces of tank and piping using vacuum, pressure, or interstitial liquid level measurements and (2) the use of vapor sensors. Please note that all other AB 2481 requirements for new s ys tems installed on or after July

1, 2003 are not affected by AB 1702. http://www.waterboards.ca.gov/ust/leak_prevention/lgs/162_1.pdf In accordance with H&S Code, Section 25290.1(e), which components of USTs installed on or after July

1, 2004 must be continuously monitored using vac uum, pressure, or interstitial liquid level measurement methods? The interstitial space of the tank and product piping (including fill, vent, and vapor recovery piping), that are beneath the surface of the ground must be maintained under constant vacuum or pressure. Statute also requires that a breach in the primary or secondary containment be detected before the liquid or vapor of the stored substance is released to the environment. Continuous vacuum, pressure, or interstitial liquid level measurement meth ods can be used to satisfy these requirements. As with all leak detection equipment used to monitor the UST sy stem, these methods must be third part y certified and should be listed in L ocal Guidance (LG) Letter 113.July

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– Interstitial Integrit y Testing 10 

### Florida http://www.dep.state.fl.us/waste/quick_topics/rules/documents/62 - 761.pdf 62 - 761.200 Definitions.

... (70) “UST Category - C sy stem” means a s ys tem that was installed on or after July 13, 1998. USTs that are removed and relocated on or after July 13, 1998 are considered Category - C sy stems. 62 - 761.640 Performance Standards for Release Detection Methods.

... (3) Internal release detection methods. (a) Interstitial monitoring for UST systems. 1. Intersti tial monitoring for double - walled tanks, double - walled integral piping, dispenser liners, piping sumps, and other secondary containment sy stems, shall be designed and constructed to allow monitoring of the space between the primary and secondary containment. One or more of the following methods of interstitial monitoring shall be used: a. Manual sampling of, or visual monitoring for, liquids; b. Continuous electronic sensing equipment; c. Hy drostatic monitoring s ys tems; or d. Vacuum monitoring. 2. Breach of integrity

tests for Category - C sy stems. A test shall be performed for a breach of integrity

of the interstice for double - walled USTs and for double - walled integral piping that is in contact with the soil and that is connected to USTs. Piping sumps and dis penser liners are not required to perform a breach of integrit y test. The test shall be performed to determine the integrity of the inner and outer wall, is required only for tanks and integral piping with closed interstices, and does not apply to open - int erstice sy stems with liners. The test shall be performed at the time of installation, and every five years from the date of installation, unless the test is a continuous test. I f a UST is totally submerged in groundwater, monthly monitoring of the intersti ce for the presence of water shall be conducted. The breach of integrit y test may be performed b y using at least one of the following methods: a. A continuous h ydrostatic system approved b y t he Department in accordance with subsection 62 - 761.850(2), F.A.C. ; b. A continuous vacuum sy stem, pursuant to paragraph 62 - 761.640(3)(a), F.A.C., that is approved b y the Department in accordance with subsection 62 - 761.850(2), F.A.C.; c. Testing of the interstice for liquid tightness in accordance with manufacturer’s ins tallation instructions; or d. Another method in accordance with subsection 62 - 761.850(2), F.A.C. 3. Vacuum monitoring of the interstice shall meet the following requirements: a. L iquid - filled gauges and air - filled gauges shall be calibrated in accordance w ith the National Institute of Standards and Technology . The gauges shall be operational at all times.July

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– Interstitial Integrit y Testing 11 b. Vacuum monitoring may be used as a continuous method of release detection provided that the vacuum s ys tem is equipped with an audible or visual alarm. The alarm shall indicate when the minimum vacuum level allowed is reached as provided in the equipment approval granted in accordance subsection 62 - 761.850(2), F.A.C. c. Vacuum readings shall be recorded monthl y. Upon discovery of an y significant vacuum le vel decrease, or any loss of vacuum exceeding 20% of the initial level, or any loss in excess of the levels established in the test protocols provided in the third part y certification for the test method, the tank manufacturer shall be contacted and the va cuum refreshed in accordance with the storage tank s ys tem’s equipment approval in subsection 62 - 761.850(2), F.A.C. If the loss of vacuum persists, an investigation shall be initiated and an incident reported in accordance with subsection 62 - 761.450(2), F.A .C. The source of the loss shall be repaired in accordance with Rule 62 - 761.700, F.A.C.July

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– Interstitial Integrit y Testing 12 

### Ohio http://www.com.state.oh.us/sfm/pub/bust_1301_7 - 9.pdf 1301:7 - 9 - 07 Release detection requir ements and methods for UST systems.

... (F) Testing methods for UST sy stems.

... (2) Tightness testing for piping.

... (c) Tightness testing of the interstice of double wall piping shall follow the manufacturers testing requirements.

... 1301:7 - 9 - 08 Operating requ irements for UST systems.

... (F) Operation of release detection components. All owners and operators shall maintain and operate release detection equipment in accordance with paragraph (F) of this rule and shall document their actions on a form prescribed b y the fire marshal in accordance with paragraph (G)(1) of this rule.

... (4) All release detection methods for piping and containment sy stems described in rule 1301:7 - 9 - 07 of the Administrative Code shall be inspected to confirm proper operation in accordanc e with the following:

... (b) Underground piping that convey s regulated substances under pressure shall meet one of the following: (i) Have an annual tightness test conducted in compliance with paragraph (F)(2) of rule 1301:7 - 9 - 07 of the Administrative Code; or (ii) Have a monthly

tightness test conducted b y the on - site electronic line testing unit provided that the unit can detect a two - tenth of a gallon per hour leak rate at operating pressure. (c) Underground piping that convey s regulated substances under suction shall meet one of the following: (i) Have a tightness test conducted every thirty - six month period in compliance with paragraph (F)(2) of rule 1301:7 - 9 - 07 of the Administrative Code; or (ii) Demonstrate compliance with paragraph (B)(3)(b) of rule 1 301:7 - 9 - 07 of the Administrative Code.

... (5) All release detection methods for hazardous substance UST s ys tems and UST sy stems located in sensitive areas as described in paragraph (C) of rule 1301:7 - 9 - 07 of the Administrative Code shall be inspected annual ly to confirm proper operation in accordance with the following:

... (c) All underground piping that routinel y contains regulated substances shall have an annual tightness test pursuant to paragraph (F)(2) of rule 1301:7 - 9 - 07 of the Administrative CodeJuly

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– Interstitial Integrit y Testing 13 

### Rhode Island http://www.dem.ri.gov/pubs/regs/regs/waste/ustreg05.pdf 8.08 Leak Detection for Existing Tanks: Ex cept as provided in Rule 8.01 above, owners/operators of all existing faci lities shall comply with the applicable leak detection requirements: (A) Double - Walled USTs: The following requirements apply to all double - walled USTs except those used for emergency generators and waste oil. These two exemptions are required to compl y wi th either 8.08 (D) or 8.08 (E). (1) Install and operate a continuous interstitial space electronic monitoring sy stem consistent with the requirements in Rules 9.15 and 9.17, and (2) Perform daily

and monthly

inventory

control and record keeping consistent with Rule 11.03, and maintain inventory records in accordance with Rule 11.02(B). (3) Perform a test for tightness on the interstitial space between the tanks walls when the tank has been installed for a period of twent y years, and once every 2 ye ars there after.July

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– Interstitial Integrit y Testing 14 

### Utah http://www.rules.utah.gov/publicat/code/r311/r311 - 203.htm R311 - 203 - 5. UST Testing Requirements.

... (c) Containment sump testing. When a sump sensor is used as a leak de tector, the secondary containment sump shall be tested for tightness annually according to the manufacturer's guidelines or standards, or b y another method approved b y the Executive Secretary .July

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– Interstitial Integrit y Testing 15 1 Unless otherwise noted, all information for California is from http://www.swrcb.ca.gov/c w phom e/ust/regulatory/docs/ccr_title23div3chapt16.pdf . See also: http://www. waterboards.ca.gov/ust/regulatory/ab2481_status.html ; http://www. waterboards.ca.gov/ust/regulatory/ab1702_enacted.html ; http://www. waterboards.ca.gov/ust/leak_prevention/lgs/160.html ; http://www. waterboards.ca.gov/ust/leak_prevention/lg113/Misc_Files/topics_lg113_vph_methods_8_13_0 4.html 2 http://www. waterboards.ca.gov/ust/leak_prevention/lgs/162_1.pdf 3 Unless otherwise noted, all information for Florida is from http://www.dep.state.fl.us/waste/quick_topics/rules/documents/62 - 761.pdf 4 Unless otherwise noted, all information for Maryland is from a June 22, 2006 phone call with Herb Meade of MDE. See also: http://www.mde.state.md.us/assets/document/OilControl/Oil_Pollution_Tank%20Man_Reg26.10.pdf ; http://www.dsd.state. md .us/comar/subtitle_chapters/26_Chapters.htm 5 Unless otherwise noted, all information for Ohio is from http://www.com.state.oh.us/sfm/fire_laws.aspx#1301_7_9 6 June 22, 2006 phone c all w ith Kevin Gillen of RIDEM. 7 http://www.dem.ri.gov/pubs/regs/regs/waste/ustreg05.pdf 8 June 22, 2006 phone call w ith Kevin Gillen of RIDEM. 9 http://www.rules.utah.gov/publicat/code/r311/r311.htm 10 June 22, 2006 phone call w ith David Wilson of UDEQ. 11 http://www.rules.utah.gov/publicat/code/r311/r311.htm 12 June 22, 2006 phone call w ith David Wilson of UDEQ.