Spill, Overfill and Secondary Containment Testing Questions (11/8/12)

**Question Crompco (Ed Kubinsk**  **y) Tank**  **nology (Brian Derge) Tait Engineering (Brian Harmon)** 

1. When y ou use water for testing sumps and spill buckets, how do y ou dispose of the water? Sometimes we pull a "water wagon" that holds several hundred gallons of water. We use the water for about a week until it becomes too dirty
for use. Then we have a vac truck come and empty it. Handling of this water is included in test price.. When not using the "water wagon", we
make sure o/o has drum on site. In some cases the customer would have to pay for disposal. for in use locations disposed of as potentially contaminated

water If the client has conducted a Fish Bioassay test approved by

California, we can transport the water from site to site, then have it disposed of as nonhazardous at an approved facility . All other liquid has to be labeled as hazardous, transported and disposed of by

a licensed company . Small quantities (under 7 gallons) can remain on site or be transported from site to site, but will have to be disposed of as a
hazardous waste.

2. How much water (volume) is used at a ty pical station with 3 spill buckets, 3 STP sumps and 4 dispensers? 100 - 150 gal/tank sump; 30 - 50 gal/UDC, and 5- 15 gal/spill bucket. Rough estimate would be about 450 - 600 gallons. ~700 gallons, estimate 150 per sump, 50 per dispenser, 5 per spill Depending upon the depth of the sumps, around 250 gallons.

3. Is disposal included as part of the cost of testing or is it an additional
cost to the owner?

Sometimes - see question 1 answer. Ty pically a separate cost We have done this both way s. Ty pically we encourage the owner to deal directly with the disposal company because we charge 15% on any invoices we pay

plus administration time (about 30 minutes to 1 hour).

4. If an additional cost to the owner, what would that cost be for the facility described in question #2? Cost varies with vac truck company . Some charge $.35/gal, others $.90/gal. Usuallly for a post construction hy

dro test at a new facility

(including sumps, dispensers, and spill buckets, cost for water disposal would be $600 to $700 Ty pically in a major metro area, the cost of water is 20 cents/gallon, vac truck ty

pically $125/hr with 4 hour min Around $900.00 to $1,100.00 depending upon mileage.

5. What percent of the time do y ou use vacuum testing (as opposed to hy drostatic testing) for spill buckets? Dispenser sumps? STP Sumps? 40%; Never; Never 75% or more; Ty pically 0% (possibly

on preconstruction prior to dispensers being set); 5% or less We do not conduct vacuum testing because we have not found a reliable sy stem that can test various manufacturers sumps or spill buckets.

1. In y our experience, does removing drop tubes associated with overfill devices cause sealing gaskets to prematurely wear or damage? On occasion, we do find worn gaskets on the drop tube, but I don' t know that removing the drop tube is the only

cause of gaskets prematurely wearing or being damaged. I think ethanol may be more of a problem. I would say

experienced and wellreained technicians are careful about removing and reinstalling drop tubes. If drop tubes are removed best practice would be to replace orings and gaskets In California we have not been removing drop tubes on gasoline tanks due to the CARB regulations. Prior to the Phase I EVR program that stated in 2001 drop tubes were installed under the fill adaptor. When the fill adaptor was removed it would cut the top O-ring and we would have to replace it. The Phase I EVR program required that the drop tube be installed below the spill bucket drain valve opening. This has reduced the number of drop tube O-rings we have to replace.

2. Have y ou found that overfill equipment can be easily damaged due to the removal, inspection and reinstallation? I wouldn't go so far as to say these are easily damaged. If the technician pulls it out quickly , it could be damaged. If he doesn't watch his step when it is lay

ing on the ground, he could step on it. If he doesn't pay

attention when reinstalling it, he could damage the flapper. The flapper valve should not be damaged on removal No, the equipment has been sturdy

.

3. How much would replacing a sealing gasket cost the owner? If we have a gasket on the truck we ty pically would replace it for free. Cost of a gasket is $4.97. Inexpensive, $5ish We charge cost plus 15%. We would not charge any labor because the technician can replace it as part of the inspection. **Water Disposal**

**Removing Drop Tubes**

1Spill, Overfill and Secondary Containment Testing Questions (11/8/12)

**Question Crompco (Ed Kubinsk**  **y) Tank**  **nology (Brian Derge) Tait Engineering (Brian Harmon)** 

1. What would be an average cost for a single spill bucket test? How about a facility

with 3 spill buckets (asking to see if the costs per bucket go down)? Would the cost be different if an owner wanted a vacuum test versus a hy

drostatic test? If so, what is the difference? $300 - $400 (mininum site charge depending on the customer); Same cost for 3 spill buckets. $50-75 for a single spill bucket test; may charge a per site fee, ty pically a min site fee in 250-300 range; we ty pically bill the same for the vac and hy dro, owner saves on disposal
with vac Assuming that the location is close to our shop, onespill bucket test would be $450.00 due to mob, demob, mileage, minimum site time, etc.. Three spill buckets at one location will cost $150.00 per bucket. These prices assume that the test water will be left on
site.

2. What would be the average cost for a single ball float inspection? How about for a facility

with 3 ball floats?

$300 - $400 (mininum site charge depending on the customer); Same cost for 3 ball floats. ~$30-50 per / unit cost *3 Single - $450; 3 devices - $450. If we have to work in a sump, our policy

is that we have a two man crew on site and treat it as a confined space entry . Also consider that we will have to conduct CARB testing if the work is conducted on a gasoline tank. All of that being said, assuming we are inspection three ball floats on a gasoline tank and have to work in a sump. The cost will be around $1,195.00 due to the two man crew and additional required testing when the inspection is done. 3. What would be the average cost for a single flapper inspection? How about for a facility

with 3 flappers? $300 - $400 (mininum site charge depending on the customer); Same cost for 3 flappers. ~$30-50 per / unit cost *3 Single - $450; 3 devices - $450. 4. What would be the average cost for a single overfill alarm inspection? How about for a facility

with 3 alarms? $300 - $400 (mininum site charge depending on the customer); Same cost for 3 alarms. Ty pically $0, performed as standard part of an atg certification/functionality test Single - $450; 3 devices - $450.

5. What would the cost be if an owner wanted to test the spill and overfill at the entire facility (3 spill buckets and 3 overfill devices)? (asking to see if cost is lower if both tests are conducted at the same time) Cost goes doen when additional services are lumped together (i.e., if testing scope of work is LTT, LD test, spill buckets, and overfill verification); So, for example: 3 spill buckets would be $300 and 3 overfill devices would be $150, making a total of $450 ty pically the more services performed the lower the the unit cost will be, the cost savings here would be based on any other testing, if this was the only work on site likely

the $300 per unit cost would hold Three spill buckets would cost $115.00 each and three overfill alarms would cost $85.00 each.

1. Are y ou aware of any

damage to secondary

containment areas for tanks, piping or sumps that might occur as a result of conducting secondary containment testing? If so, what can be damaged? tanks could be damaged if too much vacuum is applied (tech not pay

ing attention; gauges not working properly

) but I haven't heard of it happening. Piping could blow out an entry fitting or termination boot in a sump if piping is overpressurized (again if tech not pay ing attention or gauges not working properly ). I've seen fittings pop off, but if that's the case they probably weren't installed properly . I've never seen damage to a sump where testing caused problem - corrosion could be an issue if sumps aren' t cleaned out after

test. Possibly a tank annular can be damaged by too much vacuum, however this would be quite rare, would not anticipate line damage from pressure or any damage from hy dro testing of sumps The test boots and/or band clamps used to seal and test the piping secondary

have broken or torn. These are simple repairs that can be conducted while we are on site for the test. I am not aware of any other damage that has occurred due to, our company

, conducting the secondary containment testing.

2. In y our experience, how many y ears does a ty

pical tank interstitial area last before it needs to be repaired or replaced? Piping interstices? STP and UDC sumps? Tank interstice - should last for tank warranty (30

ye ars); piping unknown; estimate sumps should last 5 - 10 y ears without repair (pure estimate - no data). We warranty

any repairs we make to sumps for 1 y ear after performing a post repair test. Tanks still manufactured today ty pically last past their warranty period – discontinued tanks and some dw retro fit tanks have a seemingly

much shorter lifespan; Outside first few generations of flex piping, most of the issues here are with boots which seem to fail ty pically around a 5-7 y ear period; Similar to lines and boots more often than not the cause withstanding vintage equipment The most common failure is the secondary test boots and sump penetration fittings. When we first started secondary containment testing we had to replace a lot of sumps, piping and UDCs. Since then we have only had to replace the various fittings in the sumps or
UDCs mentions before. Most of the DW tank failures were due to the annular space riser that had to be tightened or replaced. Some of the DW tanks we have tested double wall tanks were installed in the early 1990’s and are still passing today

. **Spill, Overfill and Sump Testing Costs**

**Secondary Containment Testing and Failures**

2Spill, Overfill and Secondary Containment Testing Questions (11/8/12)

**Question Crompco (Ed Kubinsk**  **y) Tank**  **nology (Brian Derge) Tait Engineering (Brian Harmon)** 

1. What would the ty

pical costs to an owner be to go out, open 3 STP sumps and 4 dispenser cabinets and inspect/clean out those areas? How much time would the inspection, including opening and closing the sumps/cabinets, take? We perform these monthly inspection y

ou described and charge about $150 for the site visit.
It takes about 30 minutes. Cost does not include

any cost to clean out areas. Cleaning out would often require a vac truck, proper disposal and other costs we're not equipped to handle during a simple inspection. The owner could drum the waste on site, but it would cost an hourly rate of about $70/man for time spent cleaning out areas. $250-350, 1.5 to 2 hours The cost would be between $250.00 - $300.00 due to opening the sumps. Our California inspections range between $185.00 - $225.00 but do not include looking in the sumps. The inspection would take between 1.5
hours to 3 hours.

2. How might the cost change if y ou were also conducting leak detection testing in those areas at the same time? Cost doesn' t change because we run program separately from compliance testing - still $150. If a customer wanted us to do it as part of annual testing, we'd probably

reduce it by

half. relatively the same, that scope of work for a 3 tank site is ty pically a min site fee The overall price would be higher but the individual price would be less. Our pricing is based upon the hourly rate we pay

our technician.

1. What would y

ou estimate the average life of a spill bucket to be?

5-7 y ears (estimate) No good estimate, in most cases I have no idea of install date This is a tough question to answer. All of the spill buckets we have replaced failed due to damage from
an outside source or incorrect installation. As an example, some spill buckets have a flexible section that helps during installation but can be damaged by the delivery

driver’s fittings. If this part is damaged the entire spill bucket has to be replaced. Not talking about drain valves just the spill bucket, I will say that if a spill bucket is installed and used correctly they should last 15 – 20 y ears.

2. Before any

testing was required, how long would y ou estimate an owner would keep a spill bucket before replacing it? Until o/o forced to replace it based on inspector observations/recommendations or regulatory action. Most diligent o/o would replace it if needed, but these are probably the minority

. Until inspector required replacement Most of the spill bucket were replaced when the damage was noticeable. When I was testing outside of California some of the equipment was installed in the
1960’s

3. What would y

ou estimate the average life of an overfill device to be?

5-10 y ears (estimate) Getting much better, several y ears, old epoxy

sealed drop tubes were very

bad. Tubes can fail due to driver tampering. Ball floats several y

ears and atgs are long lasting in general Prior to the CARB EVR program, flapper valves would last around 5 y ears. Mostly that would fail

vapor recovery

testing and have to be replaced.

4. Before any

testing was required, how long would y ou estimate an owner would keep an overfill device before replacing it? As long as possible and until they were forced to do so per some tpe of inspection or regulatory
action. Until inspector required replacement If no testing was conducted the flapper would stay in
the tank from the date it was installed or until it failed
an allowed the tank to overfill. **Overfill Testing Results Spill Buck** 

**et and Overfill Failures and Replacements Sump Inspections** 

3Spill, Overfill and Secondary Containment Testing Questions (11/8/12)

**Question Crompco (Ed Kubinsk**  **y) Tank**  **nology (Brian Derge) Tait Engineering (Brian Harmon)** 

1. How often do ball floats Pass? Shutoffs? Alarms? best guess - can't query our sy stem. Estimates flapper valves and high level alarms probably perform the best, better than 90% passing rate for
them. If I had to choose which one I felt would be better, it would probably

be the high level alarm. Ball floats would be a little lower, may be in the high 80% range. Again, I’m sorry but I can’t provide backup for my

numbers, just an opinion. this will be highly variable depending on the area. If y ou are in an existing or recently

former stage 2 market, or required to comply with the neshap requirements, or state currently requiring overfill verification(nc, ms, al, among others) the failure rate would likely

be 15% or less. If y

ou are talking the first round of testing i would anticipate one or more of the devices would fail at 50% plus of all the locations. Ball floats are commonly

measured incorrectly , drop tubes on nonvapor markets have weep holes, etc. The ATG’s ty pically work, however are not as commonly used. Every

thing be equal(properly

installed and maintained), I would say the drop tubes fail more frequently than the atg or ball float simply due to more use, abuse, and tampering. Mechanically they work just as well, however the human factor makes them more prone to damage. Ball Floats – 15% passed Flapper Valve – 95% Passed
External alarms – 90% Passed

4