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

Question Crompco (Ed Kubinsky) Tanknology (Brian Derge) Tait Engineering (Brian Harmon)

1. When you use water for testing sumps and spill buckets, how do you 

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 typical 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. Typically a separate cost

We have done this both ways. Typically 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 hydro test at a new facility (including 

sumps, dispensers, and spill buckets, cost for 

water disposal would be $600 to $700

Typically in a major metro area, the cost of water is 20 

cents/gallon, vac truck typically $125/hr with 4 hour min

Around $900.00 to $1,100.00 depending upon 

mileage.

5. What percent of the time do you use vacuum testing (as opposed to 

hydrostatic testing) for spill buckets? Dispenser sumps? STP Sumps? 40%; Never; Never

75% or more; Typically 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 system that can test various 

manufacturers sumps or spill buckets. 

1. In your 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 you 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 laying 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 typically

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

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

Question Crompco (Ed Kubinsky) Tanknology (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 hydrostatic 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, typically a min site fee in 250-300 range; we typically

bill the same for the vac and hydro, owner saves on disposal 

with vac

Assuming that the location is close to our shop, one 

spill 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.

Typically $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

typically 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 you 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 paying 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 paying 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 

hydro 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 your experience, how many years does a typical 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 

years); piping unknown; estimate sumps should 

last 5 - 10 years without repair (pure estimate - no 

data). We warranty any repairs we make to sumps 

for 1 year after performing a post repair test.

Tanks still manufactured today typically 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 typically around a 5-7 year 

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

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

Question Crompco (Ed Kubinsky) Tanknology (Brian Derge) Tait Engineering (Brian Harmon)

1. What would the typical 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 you 

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 you 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 

typically 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 you estimate the average life of a spill bucket to be?

5-7 years (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 years. 

2. Before any testing was required, how long would you 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 you estimate the average life of an overfill device to be?

5-10 years (estimate)

Getting much better, several years, old epoxy sealed drop 

tubes were very bad. Tubes can fail due to driver tampering. 

Ball floats several years and atgs are long lasting in general

Prior to the CARB EVR program, flapper valves 

would last around 5 years. Mostly that would fail 

vapor recovery testing and have to be replaced.

4. Before any testing was required, how long would you 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 Bucket and Overfill Failures and Replacements

Sump Inspections

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

Question Crompco (Ed Kubinsky) Tanknology (Brian Derge) Tait Engineering (Brian Harmon)

1. How often do ball floats Pass? Shutoffs? Alarms?

best guess - can't query our system. 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, maybe 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 you 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 you 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 typically

work, however are not as commonly used. Everything 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 

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