Winston H. Hic kox Secretary for

Environmental

Protection Gray Davis

Governor



# FIELD EVALUATION OF

UNDERGROUND STORAGE TANK SYSTEM

LEAK DETECTION SENSORS

August 2002

State Water Resources Control Board Underground Storage Tank Program

P.O. Box 944212 Sacramento, CA 94244

www. s w r c b

. c a

. gov/cw phome/ust/

### This document was prepared by the following

State Water Resources Control Board staff:

Shahla Dargahi Farahnak, P.E., Seni or Water Resources Control Engineer

Scott Bacon, Sanitary Engineering Technician

Raed Mahdi, Water Resources Control Engineer

The following State Water Resources Control Board staff

assisted in the collection and tabulation of field data:

Eric Luong, Engineering Student Assistant

Jennifer Redmond, Student Assistant

Raul Barba, Engineering Student Assistant

Special thanks to all the regulatory agency inspectors who responded to our survey and worked with our staff in the field.

Thanks to the following individuals for thei r contributions in reviewing this document:

Mark Barolo, United States Environmental Protection Agency

Curt Johnson, Alabama Department of Environmental Management

Mike Kadri, Michigan Department of Environmental Quality

John Kneece, South Carolina Department of Health and Environmental Control

Marcel Moreau, Marcel Moreau Associates

Norwood Scott, United States Environmental Protection Agency

Tim Smith, United States Environmental Protection Agency, Region 9

Laura Chaddock, State Water Resources Control Board

Liz Haven, State Water Resources Control Board

Erin Ragazzi, State Water Resources Control Board

Michael Sahlin, State Water Resources Control Board

Barbara Wightman, State Water Resources Control Board

Thanks to the following service companies for working with our staff in the field:

Afford-a-Test Scott Co.

AllStar Service Station Systems Champion Precision Tank Testing Tait Environmental

Contract Environmental Services Tank-Tek

Ehlert Petro Maintenance Tanknology Gettler-Ryan, Inc. Tri-State Environmental Orange County Tank Testing, Inc Triangle Environmental

R.L. Stevens Vesco

Sales West Maintenance & Construction

Funding for this field evaluation was provided in part by the United States Environmental Protection Agency

## TABLE OF CONTENTS

EXECUTIVE SUMMARY .............................................................................................................. .............................1

INTRODUCTION.........................................................................................................................................................3

SCOPE OF WORK .................................................................................................................. .....................................5

O BJECTIVES OF THE F IELD E VALUATION ....................................................................................................................5

F ACILITY S ELECTION P ROCESS

............................................................................................................................... ....5

S CHEDULING AND C OORDINATION .............................................................................................................................7

D ATA C OLLECTION P ROCESS

............................................................................................................................... ......8

L IMITATIONS OF D ATA C OLLECTION ..........................................................................................................................9

UST S ENSOR F IELD E VALUATION S URVEY ..............................................................................................................10

D ATA A NALYSIS

............................................................................................................................... .......................10

FINDINGS ..................................................................................................................................................................16

A. S ENSOR D ESIGN AND P ERFORMANCE ...............................................................................................................16

B. S ECONDARY C ONTAINMENT P ERFORMANCE AND C OMPLIANCE I SSUES ...........................................................18

C. O VERSIGHT AND Q UALIFICATIONS ...................................................................................................................19

D. S ENSOR F IELD -C ERTIFICATION AND T ESTING P ROCEDURES ............................................................................20

E. M AINTENANCE AND P ROGRAMMING ................................................................................................................21

F. D ISCRIMINATING S ENSORS

............................................................................................................................... 22

G. O THER O BSERVATIONS N OT R ELATING TO S ENSORS .......................................................................................24

RECOMMENDATIONS................................................................................................................ .............................25

A. S ENSOR D ESIGN AND P ERFORMANCE ...............................................................................................................25

B. S ECONDARY C ONTAINMENT P ERFORMANCE AND C OMPLIANCE I SSUES ...........................................................26

C. O VERSIGHT AND Q UALIFICATIONS ...................................................................................................................26

D. S ENSOR F IELD -C ERTIFICATION AND T ESTING P ROCEDURES ............................................................................27

E. M AINTENANCE AND P ROGRAMMING ................................................................................................................27

F. D ISCRIMINATING S ENSORS

............................................................................................................................... 28

CONCLUSION ...........................................................................................................................................................30

APPENDICES.............................................................................................................................................................33

APPENDIX I S UMMARY OF P HASE I T ESTING (V EEDER -R OOT D ISCRIMINATING S ENSORS )

APPENDIX II W ORKPLAN FOR THE F IELD E VALUATION
APPENDIX III L OCATION OF F ACILITIES I NVOLVED IN THE F IELD E VALUATION
APPENDIX IV F IELD D ATA C OLLECTION F ORMS
APPENDIX V S ENSOR S URVEY D ISTRIBUTION L ETTER , S URVEY F ORM , R ESULTS

, AND C OMMENTS
APPENDIX VI F IELD D ATA
APPENDIX VII D ISCUSSION OF P OINT L IQUID AND P OLYMER S TRIP D ISCRIMINATING S ENSORS

## EXECUTIVE SUMMAR Y

State W a ter Resources Control Board (SW RCB) staff have been conducting a com p rehensive evaluation of the effectiveness of underground storage tank (UST) and piping system s, and associated leak detection equipm ent. The evalua tion includes: a field-based research project to

determ ine the frequency and source of releases from single and double-walled UST system s, a field evaluation of autom a tic tank gauges and autom a tic line leak detectors, a survey of statistical inventory reconciliation service providers, and a f i el d evaluation of leak detection sensors. This report contains the findings of the field evalua tion of leak detection sensors, which are the prim ary form of leak detection in double-wa lled UST system s. California’s UST population currently consists of roughly 75% double-walled system s, m a king sensor perform a nce a key

elem ent in the detection of leaks f r om UST system s statewide. The im portance of sensors will only increase as older single-walled system s are phased out of service and replaced by doublewalled system s.

Leak detection sensors are typically located in tank interstitial spaces, piping sum p s, underdispenser containm ent, and m onitoring wells within excavation liners. They m a y also be located in groundwater m onitoring wells or soil-vapor m onitoring wells surrounding the tank system

, although no such facilities were included in this field evaluation. California regulations require that all leak detection equipm ent be functionally tested and certified by an authorized service technician on an annual basis. This report was based largely on data collected from 789 sensors at 124 UST facilities during routine annual testing a nd certification. Also discussed in this report are 71 responses to an on-line survey on sensor perform a nce, com p leted by service technicians and inspectors. It is im portant to note that federal regulations and other state UST program s do not require annual certification of m onitoring equipm ent. One m a y assum e that the sensor perform a nce problem s identified in this field ev aluation would be significantly m o re com m on if California did not require the annual certification of m onitoring equipm ent.

Federal and California regulations require that leak detection equipm ent be evaluated by an independent third-party testing organization in accordance with recognized protocols. However, these evaluation protocols are designed only to te st sensor functionality in a laboratory setting. The objective of this field evaluation was to a ssess sensor functionality under field conditions.

W e also set out to determ ine the adequacy of annual certification testing procedures, and to

determ ine whether sensors in the field perform in a m a nner consistent with the specifications outlined in their third-party evaluations.

The data collected in this field evaluation dem onstrate that sensors can be a reliable form of leak detection only when properly installed, progra m m e d, m a intained, and operated. Most problem s observed in this field evaluation are due to im proper installation and program m i ng of sensors, poor or infrequent m a intenance at UST facilities, ignoring alarm s , and tam p ering with m onitoring equipm ent. Poor design, construction, and m a intenance of secondary containm ent system s were also com m on. Additionally, sensor design and m a terials played a role in som e of the failures

observed.

S W R C B 1 August 2002

### Findings - Effective perform a nce of sensors is al so dependent upon the perform a nce of the secondary containm ent in which they are installed. Therefore, this report’s findings are presented in two categories: sensor perform a nce and secondary containm ent perform a nce.

Sensor Perform a nce - Approxim a tely 12% of sensors had one or m o re problem s at the tim e of testing. The m o st com m on problem s observed were sensors raised from the low point of the secondary containm ent, sensors failing to alarm when tested, and sensors failing to shut down the turbine pum p in the event of an alarm (when program m e d to do so).

Secondary Containm ent System Perform a nce - Problem s with the perform a nce of secondary

containm ent were m o re com m on than problem s with sensors. Secondary containm ent m u st be kept clean and dry in order for sensors to perform properly; however, water was found in over 10% of secondary containm ent system s. Liquid product was present in an additional 3.5% of system s. Overall, 31% of the facilities visited in this field evaluation had water or product in one or m o re areas of the secondary containm ent system

.

Recommendations - Based on the findings of this field evaluation, we propose the following

recom m e ndations to im prove sensor perform a nce and the effectiveness of leak detection

program s based on the use of sensors:

1. Periodic inspection and functional testing of sensors and secondary containm ent are essential to reliable perform a nce. California curren tly requires annual certification of m onitoring equipm ent, and triennial integrity testing of all secondary containm ent. The United States

Environm ental Protection Agency (U.S. EPA) and states not currently requiring annual

certification of m onitoring equipm ent and periodic testing of secondary containm ent should

consider im plem enting such requirem e nts.

2. Sensor m a nufacturers should continue to refine sensor design and field testing procedures.

Sensors m u st be designed to reliably operate under the conditions found within the secondary

containm ent of an UST. Field testing proce dures should involve functional testing of the sensor, and should accurately determ ine the ability of the sensor to detect a release.

3. Standard third-party evaluation protocols for sensors should be revised to better reflect operating conditions found in the field. SW RCB UST program staff has been active in the

efforts of the National W o rkgroup on Leak Detection Evaluations to im prove the evaluation and review process.

4. 

### Regulatory agencies should call for m o re thorough training of personnel who install, service, and operate UST leak detection system s. A recent California statute requires training for these individuals, and the SW RCB is currently developing regulations to im plem ent a training standard statewide.

5. 

### Regulatory agencies m u st have authority to take enforcem ent action against UST owners and operators who tam p er with leak detection equipm ent. The SW RCB has proposed legislation that would grant regulators adm i nistrative enforcem ent authority, and allow themto “redtag” f acilities that are signif i cantly out of com p liance.

S W R C B 2 August 2002

## INTRODUCTION

Secondary containm ent for m o st UST system s has been required in California since January 1,

1984 1 

### . These “double-walled” system s em ploy liquid sensors in the interstitial space of UST

com ponents, the space between the inner and outer wall of the com ponent. Sensors are designed to detect the presence of liquid in the interstitial space, providing the prim ary (and often only)

form of leak detection in double-walled UST system s. Therefore, their reliable perform a nce is a critical factor in preventing the release of hazardous substances into the environm ent.

To com p ly with regulations and provide the m o st effective leak detection, sensors should be installed at the low point of the secondary containm ent [i.e., at the bottom of the tank interstice,

in turbine sum p s (where liquid fromleaks in double-walled piping will collect), and in underdispenser containm ent (where under-dispenser leak s collect)]. Sensors can also be found in fill

sum p s, m onitoring wells, or anywhere else leaking liquid from the prim ary containm ent m a y collect. Regardless of location, all sensors are designed to perform the sam e task: to alert the UST operator that liquid is present in the m onitored area. This alert is typically accom p lished either by activating an audible and visual alarm at a control panel, or by stopping the flow of product through autom a tic valve closure or pum p/dispenser shutdown.

California regulations require that all UST m onitoring equipm ent installed on a UST system (including sensors) be tested and certified annually by a qualified technician 2 

### . Testing and certification are often witnessed by an inspector from one of the 104 local governm e nt agencies throughout the state that im plem ent the UST regulations. The local regulatory agencies

im plem ent the statewide UST program , which is overseen by the SW RCB. As the statewide regulatory agency, SW RCB staff often receive com m e nts from technicians and inspectors about

the effectiveness of UST m onitoring equipm ent, especially if the equipm ent is not perform i ng properly. During Spring of 2000, inspectors brought the following specific concerns to our

attention:

• The inability of discrim i nating sensors to detect a layer of hydrocarbon-based product (i.e. gasoline) floating on top of water and to properly distinguish between water and product;

• The inability of polym er-strip hydrocarbon detecting elem ents to quickly and reliably

alarm ; and

• The inability of polym er-strip hydrocarbon detecting elem ents to return to effective operation (recover) after exposure to hydrocarbons.

To determ ine how pervasive the problem s were , SW RCB staff launched a field evaluation of sensors. The first phase (Phase I) of this evaluation was a cooperative effort between SW RCB staff, Veeder-Root representatives, and UST in spectors from the Santa Ana Fire Departm e nt, City of Santa Monica, and Oakland Fire De partm e nt. Phase I focused exclusively on

discrim i nating sensors m a nufactured by Veeder-Root . Data were collected from 67 Veeder-Root

discrim i nating sensors at 18 UST facilities in Phase I, between August 2000 and Novem b er 2000. Sensors were evaluated for their ability to detect and discrim i nate between product and

1 C a l i f orni a Heal t h and Safet y C ode, C h apt e r 6.7, Sect i on 25291(a)

2 California Code of Regulati ons, Title 23, Section 2637(b)

S W R C B 3 August 2002

### water, using a test m e thod proposed by UST insp ectors and further refined by Veeder-Root and

SW RCB staff. The inform ation collected provided a clearer picture of how sensors perform in the field. Although a great deal of inform ation was collected in Phase I, the data was lim ited to

Veeder-Root discrim i nating sensor m odels only.

W ith funding from U.S. EPA, we were able to conduct a second phase of field evaluations (Phase II). Phase II was conducted to evaluate the functionality of all types of liquid sensors

used to m onitor UST system s, including discrim i nating and non-discrim i nating sensors of all

m a kes and m odels. The range of objectives for Phase II was broader than that of Phase I. Field data for Phase II was collected between June 2001 and October 2001. This report includes the findings of both phases, but focuses prim arily on Phase II. A sum m a ry of Phase I testing results is included in Appendix I.

S W R C B 4 August 2002

## SCOPE OF WORK

Objectives of the Field Evaluation

The purpose of this f i eld evaluation was to assess the f unctionality of liquid sensors used to

m onitor UST system s. The focus was on “real world” effectiveness, with testing perform e d at operating UST f acilities. The f i eld evaluation was designed to:

• evaluate the f unctionality of sensors;

• check the adequacy of field-testing procedures for sensors (or work with m a nufacturers to develop field-testing procedures if they were not already available);

• determ ine whether sensors in the field perform c onsistently with their third-party evaluations;

and

• determ ine whether the standard U.S. EPA third-party evaluation protocols for sensors are appropriate for each of the sensor types evaluated.

A copy of the workplan for Phase II is included in Appendix II.

Facility Selection Process

For the first phase of this field evaluation, all facilities were located within the jurisdiction of three agencies assisting in the project; Oakland, Santa Ana, and Santa Monica. All facilities were equipped with Veeder-Root discrim i nating sensors, and all were owned by m a jor oil

com p anies. In contrast to Phase I, Phase II data were collected from a variety of sensors at a variety of facilities throughout California. An e ffort was m a de to include a wide variety of geographic locations, f acility ownership types, ta nk system conf igurations, sensor m a nuf acturers, sensor applications, and sensor operating m echanism s

.

Facility Ownership Of the 124 facilities in this field evaluation, 76 retail fueling facilities owned by m a jor oil

com p anies and 23 were retail f u eling f acilities owned by independent m a rketers. Other types of

UST f acilities were also included, such as em ergency generator f u eling f acilities, f l eet f u eling facilities, unm anned card-lock facilities, and governm e nt facilities. Figure 1 shows the distribution of facilities in this field evaluation, by ownership.

Figure 1 - Facilit y Ow nership

M a j o r Oi l Com pany
61% I ndepend ent Oi l

Com pany

19% Governm e nt al

A genc y

13% Ot her

7%

S W R C B 5 August 2002

### Geographic Location

Data from facilities within 28 local regulatory jurisdictions throughout the state were included in the field evaluation. Table 1 lists the various regulatory agencies and associated num ber of

facilities evaluated in the field evaluation. A m a p of California showing the distribution of test

f acility locations is included in Appendix III.

Table 1 - Distribution of Test Facilities,

by Regulatory Agency Jurisdictions

Agency # of

Fa cilities

Anaheim Fi re Depart m e nt 2

B u t t e C ount y Envi ronm ent a l Heal t h Di vi si on 1

C a l a veras C ount y Envi ronm ent a l Heal t h Depart m e nt 1 Orange C i t y Fi re Depart m e nt 1

C o l u sa C ount y Envi ronm ent a l Heal t h 1 Contra Costa Hazardous Materials Program 3

Frem ont Fi re Depart m e nt 2

Ful l e rt on Fi re Depart m e nt 5 Long Beach Fire Departm e nt 2 Los Angel e s C ount y Depart m e nt of Publ i c W o rks 5

M e ndoci no C ount y Envi ronm ent a l Heal t h Depart m e nt 1

M ount ai n Vi ew Fi re Depart m e nt 16 Napa County Hazardous Materials Section 3 Newark Fire Departm e nt 1

Oakl and Fi re Depart m e nt 13 Placer County Departm e nt of Environm ental Health 3

Sacram ent o C ount y Envi ronm ent a l Heal t h Depart m e nt 15

San B e rnardi no Fi re Depart m e nt 11

San Di ego C ount y Depart m e nt of Envi ronm ent a l Heal t h Servi ces 1

San Franci sco Depart m e nt of Publ i c Heal t h 2

San Leandro Fi re Depart m e nt 1

San M a t e o C ount y Envi ronm ent a l Heal t h Depart m e nt 2

Sant a Ana Fi re Depart m e nt 3

Sant a M oni ca Envi ronm ent a l Program Di vi si on 7

Sol a no C ount y Envi ronm ent a l Heal t h Servi ces 16 Torrance Fire Departm e nt 2

Yol o C ount y Envi ronm ent a l Heal t h Depart m e nt 3

Yuba C ount y Em ergency Servi ces 1

To ta l # o f Fa cilities 124



### Sensor Location

Since all m onitoring equipm ent is functionally tested during the annual certifications at which field data was collected, sensors from various locations within the tank system are included in this field evaluation. Figure 2 shows the distribution of sensors, by location within the tank

system . Note that no groundwater m onitoring well or soil-vapor m onitoring well sensors are

included in this field evaluation. W h ile we did not specifically exclude such sensors, they are very rarely used in California.

S W R C B 6 August 2002Figur e 2 - Dis t r i bu tion of S e n s or Loc a t io ns

Under D i s pens er

Cont ai n m ent

15% Tur b ine Sum p
38%

Ta n k Inte r s tice

34% E x c a vat i on Li ner
1% P i pi ng T r ans i t i on
Su m p s

1%

Fill/Va po r Su m p
11%



### Sensor Manufacturer and Operating Mechanism s Facilities f o r Phase II were selected with the intention of including a wide variety of sensor

m a nufacturers and operating m echanism s . Overall, sensor selection represented 8 different operating m echanism s and 15 different m a nufacturer s. Figure 3 shows a distribution of sensors in this field evaluation, by operating m echanism

. Figure 4 shows a distribution of sensors in this field evaluation, by m a nufacturer. In spite of our efforts to include a wide variety, the m a jority

of sensors tested were float switches m a nufactured by Veeder-Root. Such sensors are by far the

m o st prevalent in California.

Figure 3 - Sensors T ested, by Operating Mechanism

Fl oat S w i t c h

, P r oduc t P e rm eabl e
12%

Fl oat S w i t c h

68% Ul t r as oni c and

P r oduc t P e rm eabl e
5% Opt i c a l

5% Therm a l

Conduc t i vi t y
5% Ul t r as oni c

, Capac i t anc e Change

3% Conduc t i vi t y
1% M e ta l Ox id e
S e m i c onduc t o r
1%

S W R C B 7 August 2002Figur e 4 - S e ns or s T e s t e d , by M a nu fa c t ur e r

Ronan

11%

V eeder-R oot

66% Gi l barc o

7% Uni v ers a l S ens ors
4% Em co El e c tr o n i cs
2%

B eaudrea u
3% Ot her

3% Red J a c k et

2%

In co n
2%

Note: Veeder-Root and Gilbarco sensors are produced by the s a m e m a nufacturer



### Scheduling and Coordination

As part of the annual m onitoring system certification required for UST system s in California, a qualified technician m u st functionally test each leak detection com ponent. To m i nim i ze the

im pact on UST facility operations during Phase II data collection, SW RCB staff accom p anied service technicians and regulatory agency inspectors during scheduled annual m onitoring system certifications. Field data were collected while the technician perform e d this testing, and the technician’s routine test procedures were not interrupted.

Many inspectors and service technicians provided in sightful inform ation and data that would not have otherwise been obtained. In total, inspectors were present at 79 of the 106 facilities (75%)

evaluated in Phase II. In cases where regulatory agencies do not routinely have inspectors

witness annual m onitoring system s certifications, SW RCB staff coordinated with the service technicians directly. In total, technicians from 19 service com p anies perform e d the sensor testing in this field evaluation.

Data Collection Process

Data for Phase II were collected from 722 sensors in the field between May 2001 and February

2002. W h ere applicable in data analysis, data from the 67 sensors tested during Phase I were also included. During Phase II, SW RCB staff used a Sensor Data Collection Form to record the

m a ke, m odel, location, condition, response, and recovery tim es for each sensor tested. Data about facility location, UST system construction type, and personnel present were recorded on

the Site Data Collection Form . All field data collected in Phase I was recorded on the VeederRoot Discrim i nating Sensor Field Perform a nce Test Form

. 

### A copy of each form is included in Appendix IV.

S W R C B 8 August 2002

### Limitations of Data Collection

Because all Phase II data were collected with th e intent of m i nim u m im pact on the operation of the UST facility, not all of the desired tests were perform e d. For exam ple, we suggested that

discrim i nating sensors should be tested both in product and water, and that non-discrim i nating sensors be tested in water. However, m a ny disc rim i nating sensors were not tested in product, but rather by inverting or subm ersing the sensor in water. Non-discrim i nating float switch sensors were often tested by inverting the sensors, rather than by subm ersing them in water.

W h en possible, sensor response tim e was m easured from the tim e the sensor was im m e rsed in liquid (or flipped in the case of som e float switch sensors) to the tim e an alarm was activated at the control panel. In cases where the control panel could not be seen or heard from the sensor location, the tim e from sensor im m e rsion/flip to the tim e of pum p shutdown occurred was used. In cases where the control panel could not be seen or heard from the sensor location and the

m onitoring system was not program m e d for pum p shutdown, field staff would m ove between the sensor location and the control panel, m a king their best estim ate as to the actual sensor response

tim e.

Several SW RCB staff were involved in field data collection. To reduce subjectivity during data collection, staff m e t periodically throughout the evaluation to discuss the standards used in recording data. These m eetings helped m i nim i ze the im pact that inconsistent standards m a y have had on the data collection process. For exam ple, som e sensors were found near, but not quite at the lowest point of the secondary containm ent. One person m i ght consider this sensor to

be raised from the lowest point, while another person m i ght consider it close enough to the proper location to record it as being at the lowest point. Through periodic staff m eetings, standards were agreed upon and applied uniform ly by all staff involved in data collection.

Another factor that m a y have im pacted the resu lts of this field evaluation is the practice of perform i ng m a intenance at a facility just prio r to the annual m onitoring certification. Som e inspectors have stated that service technicians of ten perf orm these “pre-tests” to assure that the facility will be in regulatory com p liance and the m onitoring equipm ent will pass the annual

certification. Problem s such as failed sensors and water or product in sum p s m a y have been corrected during a “pre-test”, m eaning they woul d not show up during our field evaluation. If “pre-testing” occurred at facilities covered in this field evaluation, failure rates would be artificially lowered. Although SW RCB staff are not aware that any “pre-testing” took place, the possibility cannot be ruled out.

W h ile the findings of this field evaluation are applicable to UST system s throughout the nation,

it is im portant to note that our field data were collected exclusively in California, where annual

certification of m onitoring equipm ent is required. This m eans that a technician had already

certif ied all leak detection equipm ent at the f acilities as operational within the year prior to the

data collection. It is reasonable to assum e that failure rates m a y be higher in states where annual

certification of m onitoring equipm ent is not required, although such data are not available.

S W R C B 9 August 2002

### UST Sensor Field Evaluation Survey

To supplem ent the field data, inspectors and service technicians were polled to provide their personal experiences with sensor perform a nce. Sensor surveys were distributed to regulatory agencies and UST service technicians who work with sensors on a regular basis. W ith the help of the California Certified Unified Program Agen cy (CUPA) Forum

, an online version of the survey was also m a de available. A total of 71 surveys were com p leted, with 63 subm itted by inspectors and 8 by service technicians. Copies of the survey and transm ittal letter are included in Appendix V.

Data Analy s is

To prepare this report, data from both phases of field evaluation were entered into a database.

Additional inform ation from sensor m a nufacturers’ installation, testing, and operations m a nuals

have also been used as reference m a terials. Sensor survey results have been reviewed, and in

m o st instances they validate the field findings. However, the results of the survey are not always consistent with field data. In such cases, it is possible that survey respondents m a y have negative experiences with a specific sensor m odel’s perform a nce, which could cause them to believe that a particular problem is m o re widespread than it actually is. It is also possible that we were unable to collect sufficient field data to yield re liable findings in a particular area. In such instances, additional research m a y be needed to discover why field results differ from survey results.

Although the data collection form s and sensor surveys were designed to adequately record m o st data, there were m a ny instances where im portant inform ation could not be captured on a form

. In these cases, the “com m e nts” section was used. On the data collection form s, com m e nts describe unique facility layouts, special testing procedures, and additional details on sensor condition and perform a nce. On the sensor survey, the com m e nts include respondents’ observations of sensor perform a nce, and sugges tions on sensor im provem e nts. Com m e nts from the field data collection can be found in Appendix VI. Com m e nts from the sensor survey can be found in Appendix V.

Failure Rates, by Sensor Make and Model One objective of this field evaluation was to quantify failure rates for each sensor m a ke, m odel, and operating principle. W e attem p ted to locate and include f acilities with a variety of

m onitoring equipm ent. Although 59 sensor m odels from 15 m a nufacturers were tested, it was not possible to test a statistically significant num ber of each m odel. Therefore, no statistically valid

com p arison can be m a de between m a nufacturers’ products. Data on m a kes and m odels tested are

sum m a rized in Table 2. Sensor perform a nce data by m a nufacturer are detailed in Table 3.

Failure Rates, by Sensor Operating Mechanisms

Efforts were m a de to collect enough perform a nce data from sensors so that statistically valid

determ inations about operating m echanism s could be m a de. Sufficient data were gathered for float switch, optical, ultrasonic, and product perm eable sensors. However, only a handful of capacitance change, therm a l conductivity, or m e tal-oxide sem i conductor sensors were included in the field evaluation. Therefore, the lim ited data m a y not be a statistically valid to determ ine the reliability of these latter operating m echanism s . Sensor perf orm a nce data by operating

m echanism is detailed in Table 4.

S W R C B 10 August 2002

### Table 2 - Number of Sensors Tested and Failures, by Model

Manufacturer Model Tested Fa iled

Alpha W i re Unknown 2

B e a u d r e a u 4 0 4 1

4 0 6 2 4 3

Em co Q0003-010 2 Q 0 0 0 3

- 0 0 1 5 Q 0 0 0 3

- 0 0 2 6 Q 0 0 0 3

- 0 0 6 4

G i l b a r c o P A 0 2 5 9 1 1 4 4 0 0 0 2 4 1

P A 0 2 5 9 2 0 0 0 0 0 0 8

P A 0 2 5 9 2 0 0 0 0 1 0 1 6 1

P A 0 2 5 9 3 0 0 0 0 0

- 2 2

I n c o n T S

- I L S 1

T S P

- D I S 1

T S P

- H I S 2

T S P

- U L S 1 5 1 Mallory Controls Pollulert FD 221GTRA 3

Pollulert MD 241RRA 6 1 Mine Safety Appliances Tankgard 482607 5 2

Owens-Corning Tank FHRB 810 1

Perm A l e r t P S T V 1

Pneum e r a c t o r L S 6 0 0 L D 3

Red Jacket RE400-111-5 6

R E 4 0 0

- 2 0 3 6 Liquid Refraction (Unknown) 1

U n k n o w n 1

R o n a n L S

- 3 0 5

L S

- 3 5 9 4

L S

- 7 1 8

U n k n o w n 1

Universal Sensors LAVS-1 1 1

L A L S

- 1 2 9 2

LS 03875 STP 3

V e e d e r

- R o o t 3 3 0 2 1 2

- 0 0 1 7

3 3 1 1 0 2

- 0 0 2 2

7 9 4 3 8 0

- 2 0 8 1 7 1 3

7 9 4 3 8 0

- 2 0 9 3

7 9 4 3 8 0

- 3 0 0 1

7 9 4 3 8 0

- 3 0 1 3

7 9 4 3 8 0

- 3 0 2 8

7 9 4 3 8 0

- 3 2 0 2

7 9 4 3 8 0

- 3 2 2 1

7 9 4 3 8 0

- 3 4 1 2 6 1 1

7 9 4 3 8 0

- 3 5 0 3 9 4

7 9 4 3 8 0

- 3 5 2 5 2 1

7 9 4 3 8 0

- 4 0 8 4

7 9 4 3 8 0

- 5 0 0 1

7 9 4 3 9 0

- 2 0 5 4 0

7 9 4 3 9 0

- 3 5 2 3 3 2

7 9 4 3 9 0

- 4 0 7 2 0 2

7 9 4 3 9 0

- 4 0 9 2 2 2

7 9 4 3 9 0

- 4 2 0 8 0 2

7 9 4 3 9 0

- 4 6 0 4

8 4 7 9 9 0

- 0 0 1 6

W a rrick Controls DLP-1-NC 2 1

T o t a l 7 8 9 4 4
(Note: Veeder-Root and Gilbarco sensor s are produced by the s a m e m a nufacturer)

S W R C B 11 August 2002

### Table 3 - Sensors Failing to Alarm, by Manufacturer

Manufacturer Sensors

Tested Fa ilures Fa ilure Rate (% )

Al pha W i re 2 0 0

B e a u d r e a u 2 5 3 1 2

Em c o 1 7 0 0

Gi l b a r c o 5 4 2 4

I n c o n 1 9 1 5

M a l l o ry C ont rol s 9 1 11

M i ne Safet y Appl i a nces 5 2 40

Owens-C orni ng Tank 1 0 0

Perm Al ert 1 0 0

Pneum e ract o r 3 0 0

R e d Jacket 14 0 0

R o n a n 8 3 4 5

Uni v ersal Sensors and Devi ces 33 3 9

Veeder-R oot 5 2 1 2 7 5

W a rri ck C ont rol s 2 1 50

TOTAL 789 44 5.6



### Table 4 - Sensors Failing to Alarm, by Operating Mechanism

Operating Mechanism Sensors

Tested Fa ilures Fa ilure Rate (% )

C onduct i v i t y 9 1 1 1

Fl oat Swi t c h 539 17 3

Fl oat Swi t c h, Product Perm eabl e 97 3 3

M e t a l Oxi d e Sem i conduct o r 1 1 100 Opt i cal 3 9 3 8

Therm a l C onduct i v i t y 37 4 11

Ul t r asoni c and C a paci t a nce C h ange* 26 11 42

Ul t r asoni c and Product Perm eabl e 41 4 10

To ta l 789 44 5.6
* All sensors in this categor y were Veeder-Root model 794380-341

S W R C B 12 August 2002

### Failure Rates, by Facility Ownership The quality of installation and m a intenance procedures at a UST f acility is expected to af f e ct sensor reliability. An assum p tion was m a de that the quality of m a intenance and installation would vary depending on the type of f

acility ownership. Theref ore, an attem p t was m a de to gather and com p are data f r om a variety of types of f

acility ownership. The distribution of sensors by f acility ownership is shown in Table 5.

Table 5 - Number of Sensors Tested, by Facility Ow nership

Ownership # of

Fa cilities # of

Sensors

M a jor Oi l C o m p any 76 504 Independent Oi l C o m p any 23 177

Governm e nt al Agency 16 61

Ot h e r * 9 4 7

To ta l 124 789

* Other includes em er gency gener a tor fueling sy stem s, chem ical storage tanks, and fleet fueling facilities.



### Field data shows that failure rates were sim ilar am ong m a jor oil and independent owners. Other facility ownership types had a failure rate of r oughly twice that of the m a jor and independent oil

m a rketers, although the sam p le size for “other ow nership” was som e what lim ited. Independently owned facilities had a noticeably higher rate of raised sensors and water or product in the secondary containm ent. This m a y be attributed to less stringent construction standards, or less frequent visual inspection of the secondary containm ent. Sensor perform a nce data by facility ownership is shown in Figure 5.

F i g u r e 5 - S e n s or P e rfo rman c e , b y F a c ility Ow n e rs h i p



### 5.3 6.2 12

5.5 9 20

3.3 1.6 13

10.6

4.3 6.4

0 5 10 15 20 25

Sens or Fai l u r e s R ai s e d Sens or s * * W at er / P r oduc t i n
Cont ai n m ent * *(%) M a j o r O i l Com pany

I ndepen dent Oi l

Com pan y Governm ent al A genc y

Ot her

**Calculations based on the 722 sensor s tested in Phase I I

, since data on r a ised sensor s and

water / pr oduct in the containm ent wer e not r ecor d ed in Phase I

.

S W R C B 13 August 2002

### Performance of Discriminating Sensors Compared to Non-Discriminating Sensors

SW RCB staff have received m a ny com m e nts from inspectors and contractors, stating that

discrim i nating sensors do not perform reliably in the field. Responses to the sensor survey

echoed these com m e nts. W e targeted as m a ny f acilities with discrim i nating sensors as possible, collecting data on a total of 182 discrim i nating sensors, including the 67 tested during the Phase

I. Of these 182 discrim i nating sensors, 132 were tested in both water and product. Figures 6a, 6b, and 6c show a com p arison between discrim i nating sensors tested in water only,

discrim i nating sensors tested in both water and product, and non-discrim i nating sensors.

Because the Veeder-Root m odel 794380-341 discrim i nating sensors have such high failure rates,

and because Veeder-Root has since that tim e specified that all m odel 794380-341 sensors should be program m e d as non-discrim i nating, the perfor m a nce of discrim i nating sensors excluding the

m odel 794380-341 have also been included for com p arison.

Figure 6a - Number of Sensors Tested

50 132 106 607

0 100 200 300 400 500 600 700 D i s c r im in a t in g in W a te r On ly Di s c r i m i nat i ng i n W a t e r and P r oduc t Di s c r i m i nat i ng i n W a t e r and P r oduc t (ex c l udi ng m odel -341) Non-Di s c r i m i nat i ng S ens ors

Fi gur e 6b - Per ecnt a ge of Senso r s Fai l i ng t o A l ar m Pr oper l y W h en T est ed

2% 14% 7% 4%

0% 2% 4% 6% 8% 10% 12% 14% D i s c r i m i nati ng i n W a te r O n l y D i s c r i m i nati ng i n W a te r and P r oduc t D i s c r i m i nati ng i n W a te r and P r oduc t ( e x c l udi ng m ode l - 341) N on- D i s c r i m i nati ng S e n s or s

Figure 6c - Percent a ge of Sensors N o t at Low Point

1% 8%

0% 2% 4% 6% 8% 10% 12% 14% D i s c r im ina t in g
S ens ors Non-Di s c ri m i nat i n g
S ens ors

S W R C B 14 August 2002

### Field data shows that, when excluding the Veeder-Root m odel 794380-341 sensor,

discrim i nating sensors failed to alarm properly only slightly m o re frequently than nondiscrim i nating sensors. It is also im portant to note that discrim i nating sensors appear to be less likely to be raised from their proper location. In contrast to these findings, 77% of survey respondents stated that discrim i nating sensors were less reliable than non-discrim i nating sensors.

This m a y be due to their negative experiences with the m odel 794380-341 sensor. It m a y also

reflect the fact that our field data has an im porta nt lim itation. Due to contractors’ reluctance to

test discrim i nating sensors in product 3 

### and the difficulty in locating a wide selection of

m a kes/m odels, m a ny discrim i nating sensors were not tested in product. W ithout test data on

m o re m a kes and m odels, and without the ability to test these sensors both in product and water, it

is dif f i cult to m a ke a statistically valid statem ent regarding the relative reliability of

discrim i nating versus non-discrim i nating sensors. Table 6 lists the failure rates for all

discrim i nating sensors tested in product, sorted by m a ke and m odel.

Table 6 - Performance Data for Discriminating Sensors, by Make and Model

Mak e Model # of

Sensors

Tested in

Product # of

Failures

wh e n Tested in

Product Failure

Rate w h en Tested in

Product

(% ) # of

Sensors

Tested in

Water Only # of F a ilures

w h en Tested

in Water

Only Failure

Rate w h en Tested in

Water Only (% ) Total #

of

Sensors

Tested Total #

of

Failures Total

Failure

Rate (% )

Al p h a W i r e U n k n o w n 0

- - 2 0 0 2 0 0

Em co El ect roni c s Q 0 0 0 3

- 0 0 1 0

- - 5 0 0 5 0 0 Q 0 0 0 3

- 0 0 2 0

- - 6 0 0 6 0 0

I n c o n T S P

- D I S 0

- - 1 0 0 1 0 0

Mallo ry Co n t ro ls Po llu lert FD

221GTR A 3 0 0 0

- - 3 0 0

P o llu l e r t M D

241R R A 6 1 1 7 0

- - 6 1 1 7

R e d Jacket R E 4 0 0

- 2 0 3 0

- - 6 0 0 6 0 0

Veeder-R oot 7 9 4 3 8 0

- 3 2 0 2 0 0 0

- - 2 0 0

7 9 4 3 8 0

- 3 2 2 0

- - 1 0 0 1 0 0

7 9 4 3 8 0

- 3 4 1 2 6 1 1 4 2 0

- - 2 6 1 1 4 2

7 9 4 3 8 0

- 3 5 0 3 9 4 1 0 0

- - 3 9 4 1 0

7 9 4 3 8 0

- 3 5 2 5 6 2 4 2 9 1 3 8 5 3 4

To tal 132 18 13.5 50 1 2 182 19 10

Tot a l Excl udi ng M odel 794380-341 106 7 6.5 50 1 2 156 8 5



### Determining the Reason for Sensor Failures

It is im portant to understand what causes failures of sensors in the field. However, the reasons are not always apparent. W h en possible, SW RCB staff and the technician perform i ng the test

attem p ted to determ ine the cause of failure. In cases where the cause of failure could not be

determ ined, SW RCB staff followed up with the proper regulatory agency and/or service technician to verify that the failure was repair ed and the system was verified functional.

3 M a ny cont ract ors st at e t h at t e st i ng pol y m er st ri p di scri m i nat i ng sensors i n product i s i m pract i cal due t o excessi ve response and recovery t i m es. Furt her, som e sensors m a y not recover aft e r repeat ed or prol onged exposure t o product, thus requiring replacem ent.

S W R C B 15 August 2002

## FINDINGS

The findings of this report have been sorted into six general categories: Sensor Design and Performance

, Secondary Containment Performance and Compliance Issues, Oversight and Qualifications, Sensor Field-Certification and Testing Procedures, Maintenance and Programming, and Discriminating Sensors. These categories reflect the fact that the condition of secondary containm ent, the frequency and quality of m a intenance and testing, the level of training am ong operators and service technicians, and the quality of regulatory oversight will all

im pact the effectiveness of sensors as a leak detection m e thod. The Sensor Design and Performance section contains findings applicable to all sensors, while findings pertaining specifically to discrim i nating sensors have been included as a separate section for easy reference. A section covering Other facility Observations Not Relating to Sensors has also been included. However, there is only lim ited discussion on these observations, since they are beyond the scope

of this field evaluation

.

A. Sensor Design and Performance

1. Observation: Sensors failed to alarm properly for 5.6% of sensors tested (44 out of 789) 4



### . A list of sensor failures, by m a ke and m odel, is included in Appendix VI.

Lik e ly Cause: Causes varied, but failures are either due to defects in the sensors them selves, or defective/corroded wiring between the sensor and the control panel. Consequences: Sensors failing to alarm when tested would likely also fail to alarm in the event of a leak, leading to an increased risk of release to the environm ent.

2. Observation: Sensors can corrode over tim e. Corrosion interferes with sensor perform a nce in a variety of ways. A com m on form of corrosion was observed with Veeder-Root 794380- 420 float switch sensors installed in the interstitial space of double-walled steel tanks. These sensors have steel housings, which were frequently observed to be cracked. Corrosion can

also affect the internal com ponents of a sensor . The field evaluation showed that the m oving parts of float switches could becom e lodged in place due to corrosion. In rare instances, the float had fallen off due to corrosion of the pin that holds the float in place.

Lik e ly Cause: Materials used in the m a nufacture of sensors are not always com p atible with the stored substances, m o isture, and m a terials found in the secondary containm ent of UST

system s. Consequences: Since there is lim ited space in the interstice of steel tanks, a cracked sensor casing can m a ke it im possible to rem ove the sensor for testing. Technicians have said that such sensors occasionally have to be abandoned in the tank interstice, with new sensors

installed above them . Corrosion of internal sensor com ponents can result in m i ssed detection of product in the secondary containm ent.

3. Observation: Interstitial sensors in double-walled fiberglass tanks can becom e lodged

between the inner and outer tank walls.

4 Th is v a lu e in clu d e s 2 flo a t switch sen s o r s th at were in water with in th e su m p p r io r to testin g , b u t were n o t in

al arm

. Al t hough t h ese sensors event u al l y al arm e d when shaken vi gorousl y , t h ey were recorded as fai l u res.

S W R C B 16 August 2002

### Lik e ly Cause: Sensors are designed to be inserted into a sm all channel and wrapped around the tank, so that the sensor rests at the low point of the interstice. A pull string is used to position the sensor into the proper position within the tightly confined tank interstice. In

som e instances, the sensor becom e s lodged. Several technicians com m e nted that this m i ght be due to the inner tank settling under the weight of the product stored, effectively pinching

the sensor between the inner and outer walls. Consequences: W h en a sensor becom e s lodged in the interstitial space, it cannot be rem oved for testing. If sensors cannot be rem oved for testing, their functionality cannot be verified.

W ithout verifying functionality, a faulty sensor could go undetected, leaving the secondary

containm ent unm onitored. Further, installation of a new sensor is im practical, since the sam e physical barrier preventing rem oval of the old sensor will also prevent proper installation of a replacem ent sensor.

4. Observation: Float switches that alarm when tested m a y not alarm under leak conditions. At

two f acilities with f l oat switch sensors, a sensor was sitting in suf f i cient liquid within a sum p to activate an alarm

, but was not in alarm

. Another two f acilities had sensors with stuck

floats. The sensors went into alarm once the technician rem oved and shook them vigorously.

Lik e ly Cause: W h en inspecting turbine sum p s, staff discovered that m ovem e nt of som e f l oats was hindered by debris, preventing the alarm f

r om being activated until a technician

rem oved and shook the sensor. Consequences: Sensors that do not go into alarm because floats are lodged by debris can

result in m i ssed detection of product in the secondary containm ent.

5. Observation: Sensors failing to activate alarm s when im m e rsed in liquid was observed at

several stations.

Lik e ly Cause: The leading cause appeared to be faulty wiring, which was either installed incorrectly or had degraded over tim e. Another cause was f a ulty sensors. At one f acility,

three of four Beaudreau m odel 406 sensors installed within the under-dispenser containm ent failed due to faulty dispenser cut-offs, (sim ilar to a control panel, but designed to cut power to the dispenser when the sensor detects liquid). Consequences: Sensors failing to activate alarm s when im m e rsed in liquid can result in

m i ssed detection of product in the secondary containm ent.

6. Observation: At two facilities in the field evaluation, sensors activated alarm s when tested

but did not com e out of alarm

. Lik e ly Cause: W h ile further follow-up is required to determ ine the exact cause, technicians

at the f acility suspected a short in the wiring between the sensor and the control panel. Consequences: Leak detection equipm ent m a lfunctioning in this m a nner needs im m e diate service. Facilities with pum p shutdown will be out of service until the problem is f i xed. At facilities without pum p shutdown, an operator m a y choose to ignore the alarm

. This leaves

the m onitored area with no leak detection, and, therefore, poses a risk of release.

S W R C B 17 August 2002

### B. Secondary Containment Performance and Compliance Issues

1. Observation: Approxim a tely 6.5% of sensors tested ( 46 of 722) were not properly located at the lowest point of the secondary containm ent 5 

### . For the purposes of this field evaluation, sensors were recorded as “not at lowest point” if they appeared to have intentionally been

raised from their proper location, or if they could not be placed in the proper location due to insufficient length of wiring or a sim ilar reason.

Lik e ly Cause: In som e cases, f acility operators m a y have been raising sensors to avoid having to respond to frequent alarm s caused by surface water and/or ground water ingress into the secondary containm ent. In other cases, the design of the secondary containm ent m a y have m a de it difficult to place the sensor in the proper location, since other com ponents m a y be in the way. Sum p s that have a designated location for m ounting the sensor (such as a pipe

m ounted to the sum p wall) reduced the likelihood of raised sensors. Consequences: California regulations state that sensors should be able to detect leaks at the earliest possible opportunity 6 

### . Raised sensors are unable to detect liquid in the secondary

containm ent at the earliest opportunity, placing the facility out of regulatory com p liance and increasing the threat of a release to the environm ent. By raising sensors, f acility owners and

operators m a y also be subject to penalties f o r tam p ering with m onitoring equipm ent.

2. Observation: W a ter ingress into at least one portion of the secondary containm ent occurred at 31% of facilities (33 of 106) tested in Phase II. W a ter ingress was m o st com m on in tanktop sum p s; 18% (64 of 353) contained water. W a ter ingress was observed only occasionally in the tank interstice and under-dispenser containm ent. In 22 of the 75 cases where water was present in the secondary containm ent, the sensor was raised to prevent alarm

. The depth of water in the secondary containm ent varied from less than one inch to alm o st two feet.

Lik e ly Cause: Construction of som e secondary containm ent system s allows surface water ingress. Groundwater m a y also be entering into im properly constructed secondary

containm ent. Consequences : W a ter in the secondary containm ent leads to alarm s , which m a y prom pt the UST operator to raise or disable the sensors. W a ter also occupies volum e in the secondary

containm ent, reducing its ability to contain product in the event of a release from the prim ary containm ent. Further, water m a y accelerate deterioration of UST com ponents and leak detection equipm ent since they are not generally designed to be wet for an extended period of

tim e.

3. Observation: 11% of facilities (12 of 106) tested in Phase II had product present in at least one portion of the secondary containm ent. The presence of product was m o st com m on in tank-top sum p s, where nearly 7% (24 of 353) contained product. W a ste oil tanks often contained product in fill sum p s. The depth of product varied from less than 1 inch to approxim a tely 18 inches.

Lik e ly Cause: Releases from prim ary containm ent will collect in the secondary containm ent.
In turbine sum p s, the apparent cause of m o st leaks was faulty seals within the pum p heads.

Diesel f u el was observed m o st of ten, likely due to its slow evaporation rate. Careless f illing practices are the m o st likely cause of product in fill sum p s.

5 C a l c ul at i ons based on t h e 722 sensors t e st ed i n Phase II onl y , si nce t h i s i n form at i on was not recorded i n Phase I.

6 California Code of Regulati ons, Title 23, Section 2630(d)

S W R C B 18 August 2002

### Consequences: Product in the secondary containm ent poses a significant fire hazard, as well

as an increased risk of release to the environm ent.

4. Observation: Monitoring system s at 2 of the 106 facilities tested in Phase II were in alarm

when the service technician arrived to conduct testing. The staff on-site had not taken action in response to these alarm s

. Lik e ly Cause: UST operators m a y not have been trained in the proper response to alarm s

. Repeated false alarm s m a y lead operators to ignore them , believing that proper alarm response is not im portant. Consequences: Failure to respond to alarm s leads to an increased risk of release to the

environm ent.

5. Observation: Som e sensors are being used in applications for which they have not been designed. Sensors were used to m onitor products for which they are not certified, such as solvents, caustic chem icals, and waste oil. In one case, an interstitial sensor intended f o r use in a steel tank had been installed in a fiberglass tank.

Lik e ly Cause: Inadequate training of inspectors and installers plays a likely role in the

im proper application of sensors. Inspectors and contractors m a y not know that a sensor designed for use in unleaded fuel m a y not be effective in waste oil or certain chem icals. Consequences: Sensors used with incom p atible products m a y deteriorate m o re quickly, or

be unable to detect a release from the prim ar y containm ent. A steel tank sensor is not designed to fit within the interstice of a fiberglass tank. Steel tank sensors m u st operate in a vertical position, but a fiberglass tank interstice is designed to be m onitored with a sensor that is installed horizontally. Sensors used in applications for which they have not been designed m a y not reliably detect a release from the prim ary containm ent.

6. Observation: Degradation of the tank interstice m a de it im possible to rem ove/test sensors in

som e fiberglass tanks. It is often difficult (and som e tim es im possible) to rem ove sensors from the annular space of fiberglass tanks for inspection/testing.

Lik e ly Cause: The pull-string used to install and rem ove sensors from the tank interstice was

often m i ssing or broken, m a king it difficult for technicians to replace the sensors once they

were rem oved. The prim ary tank tends to settle within the secondary tank over tim e, effectively pinching the sensor between the walls of the prim ary and secondary containm ent. Consequences: W h en sensors cannot be tested, it is im possible to verify that they are functioning properly. For sensors that are rem oved but cannot be replaced, the tank interstice

is not m onitored.

C. Oversight and Qualifications

1. Observation: Inspectors were present for observation and data collection at 79 of the 106 of

f acilities evaluated in Phase II (75%). This rate of participation was higher than average due to interest in the field evaluation, and the f act that the inspectors had assisted SW RCB staff in coordinating inspections. The rate of inspector oversight during annual m onitoring equipm ent testing and certification is generally lower.

Lik e ly Cause: The regulatory agency’s resources do not always allow inspectors to oversee

m onitoring equipm ent certif ications at every f acility in their jurisdictions. Furtherm ore, it

m a y be difficult to coordinate the inspection with the technician conducting the certification.

S W R C B 19 August 2002

### Consequences: Coordination of annual facility inspection and the m onitoring certification allows inspectors to visually inspect sensor locations, and to verify that technicians are conducting the m onitoring certification properly. Problem s noted by an inspector can often

be rem e died im m e diately, using the skills of the service technician already present. These benefits are lost if inspection and m onitoring certification are not perform e d sim u ltaneously.

2. Observation: A wide range of knowledge and experience with sensors was observed am ong technicians and inspectors. Technicians ha d experience working in the UST field ranging

from a few m onths to over 25 years.

Lik e ly Cause: The level of knowledge seem s directly related to experience. Inspectors and

technicians that are new to the UST field are not as knowledgeable about the regulations and equipm ent as those with m a ny years of experience. Inspector expertise m a y also depend on the structure of the regulatory agency. Som e agencies have inspectors dedicated exclusively to the UST program , while other agencies cross-train inspectors in a variety of program s. Consequences: Inspectors and service technicians play a key role in ensuring that a UST

f acility is properly m a intained and regulated. Lack of proper training f o r the inspector or

service technician increases the likelihood of non-com p liant or substandard UST system s

rem a ining in operation. Such system s m a y pose an increased risk of release to the

environm ent.

3. Observation: Som e technicians perform i ng annual certification of m onitoring equipm ent do not repair or replace faulty sensors at the tim e of testing. Regulatory agencies m a y specify that sensors be repaired or replaced within a specified am ount of tim e, generally 30 days.

Lik e ly Cause: Som e technicians who conduct the annual certification of m onitoring equipm ent do not have contracts specifying that they perform repairs. Their responsibility is to test the equipm ent and report on its functionality. In other cases technicians m a y have contracts to perform repairs as needed, but do not have the necessary replacem ent parts or diagnostic equipm ent. Consequences: Facilities m a y be allowed to operate without functional m onitoring equipm ent for 30 days or longer while repairs are scheduled and com p leted.

D. Sensor Field-Certificat ion and Testing Procedures

1. Observation: Float switch sensors are often tested by flipping them rather than im m e rsing

them in liquid. Som e sensors that had been im m e rsed in water without activating an alarm

were found to activate an alarm when flipped.

Lik e ly Cause: Flipping or shaking a float switch sensor can free up a float that m a y be clogged by dirt or debris. Som e technicians believe that im m e rsing the sensor in water during testing prom otes corrosion, thus reducing the effective life of the sensor. Consequences: Manually flipping a float switch sensor is an effective m e thod of activating

an alarm condition, and verifying that m onitoring system responds accordingly. However, flipping a sensor over does not accurately sim u late the conditions a sensor encounters in the

event of a leak.

S W R C B 20 August 2002

### 2. Observation: Under-dispenser containm ent (UDC) boxes with m echanical floats and chains (i.e. Bravo Boxes) are not com m only tested. Th e inspector required functional testing of the

float-and-chain UDC leak detection device at onl y one of the 106 facilities tested in Phase II, and no test results were recorded or included in our database. Occasionally during this field evaluation, inspectors looked to see that the chains were connected. According to the few inspectors who routinely require testing of fl oat-and-chain UDC leak detection devices, the failure rate is high.

Lik e ly Cause: The com m on reasons given by service technicians and inspectors for not testing these sensors is that the process takes too long or is too difficult. Consequences: W ithout periodic testing, faulty equipm ent m a y go unnoticed. This equipm ent m a y not function properly in the event of a leak from the prim ary containm ent, leading to an increased risk of release. Additionally, undetected releases from prim ary containm ent m a y accum u late in secondary containm ent and pose a significant risk of fire, particularly in the UDC.

3. Observation: Old equipm ent is still in use at a num ber of facilities, even though the

m a nufacturers are out of business or no longer support the product.

Lik e ly Cause: As long as their old leak detection equipm ent continues to function and is in

com p liance with regulatory requirem e nts, there is no incentive for an owner to replace these

devices. Consequences: Although this equipm ent m a y still be functioning, it poses a num ber of potential problem s. Technicians m a y not be f a m iliar with operation and testing procedures for obsolete system s. If the m a nufacturer is no longer in business, there is generally no service technician training available. Technician s m a y also be hesitant to test equipm ent for which replacem ent parts are unavailable.

4. Observation: Test procedures are inconsistent. Procedures vary from one contractor to the

next and from one regulatory agency jurisdiction to the next. For exam ple, som e technicians tested float switch sensors by inverting them , while others dipped them in water. Som e therm a l conductivity sensors were tested in liquid, while other technicians blew on the sensor

to activate an alarm

. Lik e ly Cause: Many m a nufacturers do not provide detailed step-by-step field testing procedures and training. Som e technici ans m a y not have received training from

m a nufacturers on field testing procedures. In addition, som e inspectors m a y not believe that

m a nufacturers’ procedures are adequate and m a y require sensors be tested in a way other

than that recom m e nded by the m a nufacturer. Consequences: W ithout standard testing procedures, the possibility exists that inadequate procedures m a y be used. In such cases, there is no assurance that the sensors would reliably

detect releases from the prim ary containm ent.

E. Maintenance and Programming

1. Observation: The pum p shutdown (PSD) feature is not always functional. Additionally, we observed a wide range of pum p shutdown response tim es. Tim e s ranged from nearly

instantaneous to several m i nutes.

S W R C B 21 August 2002

### Lik e ly Cause: Technicians in the field attribute PSD failure to sticky relays. Factors affecting shutdown tim e include control panel m odel, software version (particularly with the Veeder-Root/Gilbarco panels), and com p lexity of leak detection equipm ent at the f acility. (For exam ple, the m o re sensors at a f acility, the slower the shutdown). Consequences: Pum p shutdown failure could result in piping sum p s or under-dispenser

containm ent overflowing in the event of a catastrophic piping failure.

2. Observation: In m a ny instances, a console had not been program m e d according to the

f acility m onitoring plan.

Lik e ly Cause: Many m onitoring equipm ent m a nufacturers provide the user with a variety of set-up and alarm options f o r their f acilities. These options include activating pum p shutdown, indicating a warning instead of an alarm

, or dialing out to a rem o te location in the

event of an alarm condition. In cases where the console set-up did not m a tch the m onitoring plan, it is possible that the console was not program m e d correctly at the tim e of installation. Program m i ng m a y also have been changed, intentionally or inadvertently, either at the

console or rem o tely via a m odem connection. Consequences: Program m i ng of the m onitoring console affects sensor perform a nce and the ability to properly alert an operator in the event of a problem . Im proper program m i ng m a y also place a facility out of regulatory com p liance.

F. Discriminating Sensors

1. 

### Observation: Although field staff requested that discri m i nating sensors be tested in water and product, this was only done 56% of the tim e (65 of 115 discrim i nating sensors) 7



### . Lik e ly Cause: Many technicians and inspectors are hesitant to test discrim i nating sensors in product due to the long response and recovery tim es. There is also a concern that the sensors

m a y not recover after being exposed to product, and will have to be replaced. Consequences: Unless a discrim i nating sensor is tested in product, the functionality of one of its operating m odes is not verified. Since the sensor’s full perform a nce is not determ ined, there is an increased possibility of m i ssed detection.

2. Observation: Many of the Veeder-Root 794380-341 sensors (shown in Figure 8) exposed to product indicated a water alarm

. This problem was observed in 13 of 26 m odel 794380-341 sensors in the first phase of testing, and 9 of 17 in the second phase. Overall, the m odel

794380-341 sensor failed to alarm properly approxim a tely 50% of the tim e. Lik e ly Cause: Since this problem is specific to the m odel 794380-341 sensor, there is likely a design or m a nufacturing flaw. Consequences: UST owners and operators generally consider response to water less urgent response than product alarm s . Therefore, product in the interstitial space that is falsely identified by the sensor as water m a y pose an increased risk of release to the environm ent.

3. Observation: Response and recovery tim es of the polym er strip elem ent when exposed to

fuel were som e tim es excessive, and not always consistent with third-party claim s . Response

tim es in a gasoline/water m i xture ranged from 5 to 12 m i nutes, with an average of

7 Does not i n cl ude sensors t e st ed duri ng Phase I, si nce t e st i ng i n product was m a ndat e d duri ng t h at phase.

S W R C B 22 August 2002

### approxim a tely 7 m i nutes. Recovery tim es in gasoline ranged from 1 m i nute to over 50

m i nutes, with an average of approxim a tely 17 m i nutes (see Figure 7). 8



### Lik e ly Cause: The fuel alarm is activated only after enough fuel has perm eated the polym er strip to raise its electrical resistance to a set value. Typically the resistance in the strip did not begin to change appreciably for several m i nutes. Consequences: A prim ary concern with polym er strip discrim i nating sensors is the am ount
of tim e they take to alarm

. In the event of a catastrophic leak from pressurized piping, the slow response tim e could allow for a large release of fuel into the UDC or containm ent sum p before the alarm sounds. W h en the liquid level reaches the high-level liquid set point, a high-level water alarm will sound. It could still be m a ny m i nutes before the polym er strip

reacts to the fuel and activates a fuel alarm

. This could be a m a jor concern if the system is not configured for turbine shutdown when the high-level water alarm is activated. An additional concern is the wide variation in response tim es from one sensor to another. W ith such variation, it is difficult to determ ine exactly how long a polym er-strip sensor should typically take to alarm once exposed to fuel, to establish field-testing guidelines, or to

determ ine if a sensor is actually non-functional or just slow to respond.

F i g u r e 7 - R

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T i m es f o r

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e ed er
- R o o

t M o d e l 7943 80- 3 5 2

P o l y m e r S t r i p D i scr m i n i at i n g S e n s o r s T est ed i n G aso l i n e / W

at er M i x ( P h ase I )

0 8 16 24 32

0 5 10 15 20 25 30 35 40 45

Se n s or sTime (min.) T i m e to A l a r m

T i m e to R e c o

v e r

Thi r d- P a r t y
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y T i me ( 1 7. 2 m i nu t e s)

Thi r d- P a r t y
V

a l ue f o r
R e p ons e Ti m e ( 1 0 m i nut es) M a x Value: 52 M i nutes

S W R C B 23 August 2002 8 A t horough di scussi on on response and recovery of pol y m er st ri p di scri m i nat i ng sensors can be found i n t h e “Sum m a ry of Test R e sul t s from Phase I Test i ng,” whi c h i s i n cl uded i n Appendi x I.

### 4. Observation: Current third-party protocols m a y not be appropriate for polym er-strip sensors.

Lik e ly Cause: Third-party evaluators have been using a standard liquid point detection protocol to evaluate polym er-strip sensors. These protocols are designed for m e chanical or electrical switching devices that do not use chem ical reactions like the polym er strips. The protocol does not take into account factors that m a y affect polym er-strip sensors. The ability

to alarm and recover in a variety of environm ental conditions is not assessed. The im pact on response tim e and recovery tim e after repeated fuel exposure of these sensors is not

evaluated. Consequences: Sensors m a y fail to detect a product release in the field, not respond quickly under certain conditions, and not recover once exposed to product.

5. Observation: Som e discrim i nating sensors m a y not be able to detect product floating on

water.

Lik e ly Cause: Hydrocarbons typically float on water, and m o st discrim i nating sensor designs require the sensor to be in contact with product in order to detect it. Therefore, som e discrim i nating sensors will not detect product release when sufficient water is present. The

level of water that will result in a m i ssed detection varies depending on sensor design. Designs can be divided into two general categories: Point Liquid Type and Polym e r Strip Type. Each of these categories has distinct capabilities and lim itations, as described in Appendix VII. Consequences: Sensors m a y not detect a product release when water is present in the secondary containm ent, which m a y pose an increased risk of release to the environm ent.

G. Other Observations Not Relating to Sensors

The following observations do not directly relate to the effectiveness of sensors as a m e thod of leak detection, but are com p liance related item s that pose an increased environm ental risk.

Discussion of these observations is lim ited because they are beyond the scope of this field evaluation, but follow-up and enforcem ent action m a y be appropriate.

1. Line leak detectors (LLDs) have a high failure rate when tested with a 3.0 gallons per hour at 10 pounds per square inch leak rate. All staff collecting data for this field evaluation observed failures, although LLD failure data were not recorded. In general, m echanical

LLDs failed m o re frequently than electronic LLDs. SW RCB staff are currently evaluating the effectiveness of LLDs in the field as part of a separate project.

2. Som e UST facilities had recently installed under-dispenser containm ent (UDC), but did not

install m onitoring devices as required by California regulations 9 

### . In one case, a sm all leak

from the dispenser piping had resulted in nearly 18 inches of diesel fuel in the UDC. In this case, it appeared that the presence of UDC prevented a release to the environm ent. However, the leak had gone undetected for som e unknown tim e period, and would have rem a ined undetected if the annual facility com p liance inspection were not being perform e d that day.

3. The overfill prevention devices had been tam p ered with at one facility. Long sticks had been

inserted and lef t in the f ill pipes, ef f ectively disabling the f ill tube positive overf ill protection

device. Com m e nts from technicians and inspector s indicate that this is not uncom m on.

9 California Code of Regula tions, Title 23, Section 2636(f)

S W R C B 24 August 2002

## RECOMMENDA TIONS

The following recom m e ndations are designed to im prove the effectiveness of sensors as a leak

detection m e thod by addressing specific issues obs erved during this field evaluation. Just like the “findings” section of this report, recom m e ndations are organized into six categories: Sensor Design and Performance

, Secondary Containment Performance and Compliance Issues, Oversight and Qualifications, Sensor Field-Certification and Testing Procedures, Maintenance and Programming, and Discriminating Sensors. The Sensor Design and Performance section

contains recom m e ndations applicable to all sensors, while issues pertaining specifically to

discrim i nating sensors have been included as a separate section for easy reference. Note that no specific recom m e ndations have been m a de to address the findings listed under Other Facility Observations Not Relating to Sensors , since these are beyond the scope of work for this report.

A. Sensor Design and Performance

• Improvement in the design and manufacture of sensors is needed. The results of this

field evaluation indicate that the environm ent in which UST leak detection sensors operate can degrade their perform a nce over tim e. Manufacturers should design sensor housings, wiring, and functional elem ents to endure UST system conditions for the anticipated life of

the sensor.

• Float sw itch sensor design should allow for free movement of the float. For a float switch sensor to operate effectively, the float m u st be free to m ove up and down in response to the presence of liquid in the secondary containm ent. Manufacturers should produce float switch sensors that are not easily obstructed by dirt and debris, or are in an enclosed housing that keeps debris away from the float m echanism

.

• All sensors should be evaluated under field-representative conditions. Standard U.S. EPA evaluation protocols should be re-evaluated by a workgroup of inspectors,

m a nufacturers, and third-party evaluators. Modi fications to the protocols should be m a de to assure that the evaluation challenges the sensor’s perform a nce under conditions likely to be encountered in the field. Once the new protocol is in place, only sensors that have been evaluated by an independent third party in accordance with the revised protocol should be approved for new installations.

• Sensors should not be used as the sole method of leak detection for double-w a lled pressuriz e d piping. This field evaluation has shown that, for a variety of reasons, sensors

m a y fail to detect a release from the prim ary containm ent. Therefore, a line leak detector or other leak detection should be used as a backup. This will reduce the risk of release to the

environm ent in the event of a catastrophic failure of the prim ary piping.

S W R C B 25 August 2002

### B. Secondary Containment Performance and Compliance Issues

• Secondary containment should be designed and constructed to prevent the ingress of surface and ground w a ter. Preventing water ingress will reduce the f r equency of water
alarm s from sensors in the secondary containm ent. It will also help reduce the tendency of facility operators to raise their sensors to avoid water alarm s , and would reduce the am ount
of water that has to be rem oved from the cont ainm ent and disposed of properly. Finally, any

adverse im pact that water m a y have on sensors (such as corrosion or accelerated failure of

internal com ponents) would be m i nim i zed by keeping water out of the secondary

containm ent.

• Secondary containment should be tested periodically. Testing will verif y that the

containm ent is capable of holding product in the event of a release. Testing will also identify points where groundwater m a y enter the containm ent. Once identified, these points can be repaired in order to prevent groundwater intrusion into the secondary containm ent.

C. Oversight and Qualifications

• UST operators should be trained about thei r role in effective leak prevention. The m o st

com m on problem observed in this field evaluation was raised sensors. In m a ny of these cases it is likely that the f acility operator raised the sensor in order to disable it, or to take it

out of alarm when liquid was in the secondary containm ent. Tam p ering with leak detection is a regulatory violation, and individuals ca ught doing so m a y be subject to penalties and fines. Raising sensors m a kes the leak detection system less effective, thus increasing the risk

of release of hazardous substances to the environm ent. Training UST owners and operators on proper alarm response and the consequences of tam p ering with m onitoring equipm ent will help reduce this problem

.

• Enforcement action should be taken agai nst those w h o intentionally hinder the effectiveness of leak detection equipment. This includes tam p ering with sensors, ignoring

alarm s , turning off m onitoring system s, or failing to take action when product or water is present within secondary containm ent. Enforcem ent action m a y also be appropriate for other

violations that increase the risk of release to the environm ent, such as tam p ering with overf ill prevention equipm ent.

• UST inspectors w o uld benefit from additional training on the limitations and proper application of sensors. Som e sensors were installed incorrectly f o r the specif i c conditions at a particular UST facility. Facility-specific conditions included the type of product stored and the size or shape of the m onitored space. By better understanding how each type of sensor operates, regulators can m a ke m o re inform ed decisions about the appropriate application and placem ent of specific sensors when reviewing and approving m onitoring plans.

S W R C B 26 August 2002

### D. Sensor Field-Certificat ion and Testing Procedures

• All sensors should be functionally tested at least annually. This annual testing should include under-dispenser containm ent boxes with m echanical floats and chains (i.e. Bravo Boxes). Testing procedures should also incl ude verification of alarm s and pum p shutdown where applicable. Monitoring system s that provide shutdown of the pum ping system when

sensors are disconnected and/or when the m onitoring system loses power should also be functionally tested.

• Testing should be conducted by a qualified service person. Service technicians should be knowledgeable about UST m onitoring system s, and should be trained the m a nufacturers of the equipm ent they are working with. Periodic testing should verify functionality of the sensor, and should be conducted in accordance with the m a nufacturer’s recom m e nded protocols, in a m a nner consistent with all applicable regulations.

• A standard field test procedure should be developed for each sensor technology. The procedures should dem onstrate each sensor’s ability to reliably detect a leak (for exam ple, float switch sensors should be tested in liquid rather than by flipping). Manufacturers should work with technicians and regulators to deve lop these testing procedures, and should train service technicians to perform the testing properly. Technicians should be required to conduct testing in accordance with standard procedures once such procedures are in place.

E. Maintenance and Programming

• Secondary containment should be inspected fre quently to verify that it is clean and free of liquid (w ater and product) and debris. This field evaluation showed that, due to a variety of factors, sensors were not 100% effective at detecting liquid in secondary

containm ent. Therefore, it is im portant to perform frequent visual inspection of these areas.

W e recom m e nd that visual inspections be conducted on at least a m onthly basis.

• Float sensors should be inspected frequently (more than once a year) to verify that they

are functional. Float sensors m a y not work properly if debris and dirt within the secondary

containm ent interferes with the m ovem e nt of th e float m echanism

. In order to have effective

m onitoring of secondary containm ent using float sensors, frequent inspections and

m a intenance is im portant. This recom m e ndation is particularly significant given the prevalence of float sensors (68% of sensors in this field evaluation).

• Sensors installed in piping sumps to monitor pressuriz e d piping should be programmed

to shut dow n the pump w h en product is detected. Most m onitoring system s are capable of this function if they are program m e d accordingly. Program m i ng the m onitoring system to shut down the pum p when a leak is detected in the piping is a sim p le, inexpensive way to

reduce the risk of release of hazardous substances to the environm ent.

S W R C B 27 August 2002

### F. Discriminating Sensors

• Veeder-Root model 794380-341 sensors should not be used as discriminating sensors. The field testing dem onstrated they are unable to discrim i nate between water and product nearly half of the tim e. However, they were able to reliably determ ine the presence of liquid. Therefore, all alarm s from the m odel 794380-341 sensors, whether water or product, should be treated identically. Consoles should be program m e d accordingly, and Veeder-Root has

issued a statem ent to this effect. W e further recom m e nd that all m odel 794380-341 sensors

that fail the annual m onitoring certification be replaced with a different m odel.

• Discriminating sensors should be tested in w a ter and product as part of the annual monitoring certification. Since discrim i nating sensors are program m e d to respond differently in product than in water, and si nce different alarm s m a y receive different responses from on-site staff, it is im portant to verify that the water and product detection capabilities of the sensor are functional. If long response and recovery tim es m a ke such testing im practicable, the use of a different type of sensor should be considered.

• A new evaluation protocol should be develo ped to effectively evaluate polymer strip

sensors 10 

### under field-representative conditions that may impact their performance. The protocol should assess the sensor’s ability to respond to hydrocarbons in a variety of

environm ental conditions, and the im pact that repeated/prolonged exposure to product m a y have on the sensor’s ability to alarm and recover f r om alarm reliably. Since current evaluation protocols do not cover these key perform a nce factors, no new polym er strip sensors should be installed until new evaluation protocols are in place and the sensors have been certified in accordance with those protocols.

• Water alarms from point liquid discriminating sensors should receive a rapid response. Since point liquid discrim i nating sensors can onl y respond to the liquid directly in contact

with the detection elem ent, they are unable to detect a product release floating on an existing pool of water whose height exceeds the level of the detection elem ent. To m i nim i ze the risk

of m i ssed product detection with these sensors, it is im portant that water alarm s be responded

to prom ptly and owners and operators be trained on the lim itations of these type of

discrim i nating sensors. Regulatory agencies should consider the lim itations of these sensors when reviewing m onitoring plans.

• When installed in turbine sumps and UDC, po lymer strip discriminating sensors with

low and high level liquid alarms should ac tivate pump shutdow n for both product and high-level liquid alarm. Once the water level has risen above the high-level float, floating product will not com e in contact with the polym er cable or strip. There is essentially no leak detection once water reaches the high-level float, so all sensors of this type which are

m onitoring pressurized piping should be progr am m e d to shutdown the pum p at high liquid level. Proper console configuration and ope ration of the pum p shutdown feature should be verified during the annual m onitoring certification.

10 See Appendi x VII for a descri pt i on of pol y m er st ri p and poi nt l i qui d sensors.

S W R C B 28 August 2002

### • Longer response times associated w i th polymer strip discriminating sensors may make them inappropriate for use in certain applications . Polym e r strip discrim i nating sensors

are m u ch slower to respond to hydrocarbons than other sensor types. Therefore, care m u st be taken when considering their use. Polym e r strip discrim i nating sensors should not be used as

the sole m onitoring m e thod for double-walled pressurized piping unless they are

program m e d to shut down the pum p when exposed to water or product.

• Polymer strip discriminating sensors should not be used in UST systems storing diesel.

Since diesel fuel is not as volatile as unleaded fuel, polym er strips respond m u ch m o re slowly (response tim es in diesel fuel m a y be 12 hours or m o re.) The lengthy response tim e of polym er-strip sensors in diesel fuel poses an increased risk of release to the environm ent.

• Monitoring plans for facilities w i th discri minating sensors should include response plans for both w a ter and product alarms. Leaving water in the secondary containm ent for

an extended tim e period is unacceptable. The m o st appropriate solution for dealing with water in the secondary containm ent is to m a ke the containm ent system s water tight. California’s program of periodic integrity testing of secondary containm ent system s should help m i nim i ze water intrusion problem s, by identifying and repairing leaks through which groundwater m a y enter. Regulatory agencies should review response plans to assure that response tim es for water and product alarm s are appropriate based on facility-specific

conditions.

• Discriminating sensors may be reprogramme d as non-discriminating if needed. In response to the recom m e ndations of this report, or to com p ly with local ordinances, UST

operators m a y wish to replace their discrim i nating sensors with a non-discrim i nating m odel. As an alternative to replacem ent, m a ny discrim i nating sensors can be reprogram m e d to operate as non-discrim i nating. Reprogram m i ng can be a cost-effective solution for

discrim i nating sensors that m a y not be providing ef f ective leak detection or satisf y ing local

ordinances. Note that only a representative authorized by the m a nufacturer should perform this reprogram m i ng.

S W R C B 29 August 2002

## CONCLUSION

The results of this field evaluation indicate that se nsors can be an effective form of leak detection only when properly installed, program m e d, and m a intained. Im proper operation, poor

installation and m a intenance practices, deficiencies in the construction of secondary

containm ent, and poor design of som e sensors was observed during the field evaluation. W h en including instances of water or product in the secondary containm ent, raised sensors, ignored

alarm s , and failure of the pum p shutdown feature, 12% of the sensors tested had a problem . The problem s identified m a y well be even m o re com m on in states not requiring annual certification

of m onitoring equipm ent.

To m a ke sensors a m o re effective form of leak detection, im provem e nts are needed in the following areas:

Functionality of Sensors

 Manufacturers should consider im proving sensor design and m a terials to m a ke them

m o re durable. Sensors should be designed and m a nufactured to operate under the conditions present at operating UST f acilities.

 Sensors should not be used as the sole form of m onitoring for double-walled pressurized piping. Line leak detectors should be require d as additional protection, to reduce the risk

of release to the environm ent in the event of a catastrophic release from the prim ary piping.

 Polym e r strip discrim i nating sensors should not be used to m onitor for the presence of less volatile hydrocarbons, such as diesel and waste oil.

Field Testing Procedures

 Periodic functional testing of sensors is critical to their effectiveness. Functional testing should be perform e d at least on an annual basis. However, m o re frequent visual inspection and preventative m a intenance is recom m e nded for all float switch sensors.

 Manufacturers should develop standard field testing procedures, and technicians should be trained on how to conduct field testing pr operly. Once test procedures are in place, technicians should be required to follow them . Test procedures should dem onstrate a sensor’s ability to detect a release (f or exam ple: testing in liquid f o r f l oat switch sensors, and testing in both water and product for discrim i nating sensors).

Third-Party Evaluation of Sensors

 Current third-party certification test protocol s for sensors should be m odified to better

and m o re thoroughly evaluate sensors, and subject them to the param e ters present at operating UST f acilities.

Regulatory and Technical Oversight

 Training is needed for UST owners, operators, installers, service technicians, and inspectors. Training should cover proper application, installation, testing, program m i ng, and operation of sensors, as applicable.

S W R C B 30 August 2002

###  Enforcem ent action should be taken against those who tam p er with sensors, ignore

alarm s , turn off m onitors, or fail to take action where product or water is present within secondary containm ent.

Design and Construction of Secondary Containm ent

 Secondary containm ent should be designed, installed, and m a intained to be water tight. This will help reduce the f r equency of raised sensors and water alarm s , and help prevent deterioration of the sensors and secondary containm ent.

 Secondary containm ent should be tested periodically. Periodic testing will help assure that secondary containm ent can prevent groundwater ingress and contain product in the

event of a leak.

S W R C B 31 August 2002Winston H. Hickox Secretary for

Environmental

Protection Gray Davis

Governor



# FIELD EVALUATION OF

UNDERGROUND STORAGE TANK SYSTEM

LEAK DETECTION SENSORS

- Appendices -

August 2002

State Water Resources Control Board Underground Storage Tank Program

P.O. Box 944212 Sacramento, CA 94244 www.swrcb.ca.gov/cwphome/ust/

# TABLE OF CONTENTS

APPENDIX I Summary of Phase I Testing (Veed er-Root Discriminating Sensors)



# APPENDIX II Workplan for the Field Evaluation



# APPENDIX III

Location of Facilities Involved in the Field Evaluation



# APPENDIX IV

Field Data Collection Forms



# APPENDIX V Sensor Survey Distribution Letter, Survey Form, Results, and Comments



# APPENDIX VI

Field Data



# APPENDIX VII Discussion of Point Liquid and Poly mer Strip Discriminating SensorsAPPENDIX ISummary of Phase I Testing (Veeder-Root Discriminating Sensors)November, 2000

Appendix I, Phase I Testing Summary Page 1 of 9 Figure I - A typical multi-element discriminating sensor

with float switches and a product solubility element. 

# Phase I Testing Summary

(Field Evaluation of Veeder -Root Discriminating Sensors)

Introduction Sensors are used in a variety of places within a UST system to detect a release of product. For double-wall systems, they are either located in side the secondary containment (sumps and under dispenser pans) or in the space between the pr imary and secondary containment of the tank or piping, known as the interstitial sp ace. Field experience has show n that due to numerous design, installation, and maintenance issu es these areas are often not ke pt clean of water intrusion or

excessive condensation. This has led the indus try to introduce sensors that are capable of differentiating between water and hydrocarbons. Thes e sensors are referred to as “discriminating

sensors.”

Discriminating sensors can provid e distinct alarms for water or product. Some even offer distinct alarms for low and high levels of water. Depending on how the control panel is programmed, a product or water (low or high leve l) detection can activat e a warning, alarm, or pump shutdown. Typically, se nsors are programmed to provide a warning when water is detected, which still allows the UST system to operate. Product detection is typically programmed to activate a fuel alarm, and may also automatically shut down the pump.

There are two basic approaches to discrimina ting sensors, as described in the following paragraphs. One approach to discriminating sensors is to combine two or more sensing elements into a single unit (See Figure I). This approach is well suited for sumps where surface water is prone to leak in, presenting the possibility of product floating on water. Sensing elements (most often a float switch) are used to detect low and high liquid levels . If the level rises above a preset point, the sensor notif ies the operator by activating an alarm or warning message on a control panel. A hydrocarbon-sensing element (s uch as a product permeability sensor) is also incorporated to detect the pr esence of product. The combination of these multiple sensing elements into a single unit makes a discriminating sensor able to determine the presence of water versus hydrocarbons. There are several combina tions of detection mechanisms that may be incorporated in a single unit to produce a discriminating sensor.November, 2000

Appendix I, Phase I Testing Summary Page 2 of 9



### The second type of discriminating sensor uses only one detection mechanism, but is able to discern between product and other liquids based on some specific property of the liquid. Some adsistor, capacitance change, el ectrical conductivity, fiber optic chemical, and thermal conductivity sensors are sophisticated enough to distinguish between product and water.

Purpose of the Project This report is based on test ing performed only on discriminating sensors manufactured by Veeder-Root, as they are the most prevalent in California. We initiated a field study of discriminating sensors in response to local agency concerns that some of these sensors did not appear to operate properly when annual main tenance certification and inspections were conducted. Particular items of concern brought to our attention by local ag ency inspectors were:

• The inability of discriminating sensors to de tect a layer of hydrocarbon-based product (i.e. gasoline) floating on top of water and to pr operly distinguish betw een water and product;

• The inability of polymer-based hydrocarbon det ecting elements to alarm in a reasonable amount of time; and

• The inability of polymer-based hydrocarbon det ecting elements to return to effective operation (recover) after e xposure to hydrocarbons.

While this project was initially designed to a ddress the aforementioned local agency concerns, we enlisted the help of discriminating sensor manufacturers and local agency inspectors to expand the scope of the study. The scope of the study included:

• Evaluating the functionality of discriminati ng sensors used in Ca lifornia (in response to

the above listed concerns of local agency inspectors);

• Checking the adequacy of field-testing pro cedures for discriminating sensors (or work with manufacturers to develop field-testing proc edures if they are notalready available);

• Determining if discriminating sensors in the field perform consistently with the specifications outlined in thei r third-party evaluations; and

• Determining if the third-party evaluation protocol currently used is suitable for the sensor types tested using that protocol.

Coordination of the Field Testing Since the focus of the testing wa s on the performance of sensors in the field, it was necessary to conduct testing at operating faci lities where the sensors are in stalled. Three local agencies representing a cross section of California’s UST population local regulatory governments volunteered to assist with this pr oject. The City of Santa Ana, C ity of Santa Monica, and City of Oakland helped us to identify facilities within their jurisdictions that were using Veeder-Root discriminating sensors. In order to minimi ze the impact on owners , operators, and local agencies, we scheduled our field testing to coinci de with the required a nnual inspections. The maintenance contractor performed the testing for the sensors while completing all the other

scheduled annual certification work. Manufact urer’s representatives were on hand to observe the testing, assist with the advan ced setup and diagnostic features of the sensor control panel, and to answer technical questions.

Testing Procedure

In order to test the sensors during this evaluation, Veeder-R oot prepared a draft testing procedure. We reviewed and provided comments on the draft test procedures, which were thenNovember, 2000

Appendix I, Phase I Testing Summary Page 3 of 9



### modified by Veeder-Root and re-submitted as a s econd draft. The second draft was the testing procedure used in our field evaluation. Modifications we re made throughout the study, as deemed necessary by our staff on site. Modi fications were included to minimize station downtime, and to test possible improvements to th e protocol (such as th e cleansing of sensors in white gas 1 

### to accelerate recovery of polymer strips.)

The basic test procedure was to immerse the discri minating sensor in fuel, water, or a fuel/water mixture to see if it alarmed appropriately (e.g., wa ter and/or fuel). We modified the procedure by using a stopwatch to determine the length of time between sensor immersion and alarm, and the length of time for the sensor to recover af ter being removed from the liquid. We also noted the type and the depth of the liqui d in which a sensor was immerse d, as well as the type of alarm (fuel, water, or both water a nd fuel) the sensor registered.

Test procedures varied slightly between sens or models, due to differences in detection mechanisms. Veeder-Root’s discriminating sensor s can be classified in two general families based upon their fuel-sensing mechanisms: Ultrasonic sensors (model 794380-341), and Polymer Strip Sensors (all other models tested). Tabl e I lists the Veeder-Root discriminating sensors tested in this study, including the mechanisms each sensor model uses to determine the presence of liquid and/or fuel, and the te sting procedure used in our study.

TABLE I - Veeder-Root’s Discriminating Sensors

Model

Number Application VR Test

Procedure Water Sensing

Mechanism Fuel Sensing Mechanism

794380-320 Dispenser Pan A Ultrasonic Polymer Strip

794380-350 Sump (Pump or Piping) A Ultrasonic Polymer Strip

794380-322 Dispenser Pan A Float Switch Polymer Strip

794380-352 Sump (Pump or Piping) A Float Switch Polymer Strip

794380-360 Fiber Trench A Ultrasonic Polymer Strip

794380-361 Fiber Trench A Ultrasonic Polymer Strip

794380-362 Fiber Trench A Ultrasonic Polymer Strip

794380-341 Interstitial B Ultrasonic Capacitance Change



### Data Collection

City of Santa Ana SWRCB staff, local agency inspectors, maintenance contractors, and Veeder-Root representatives collected data fo r this project. Data collecti on began in Santa Ana in August 2000, where the local agency inspector, mainte nance contractor, Veed er-Root representatives were present at each testing site. SWRCB sta ff was present at some of the Santa Ana sites. Veeder-Root representatives recorded the test data in Santa Ana. This data was forwarded to us for analysis. (See Table II for a summary of this data.)

1 Since the time of testing we have heard from other manufacturers of polymer strip sensors that this practice, although common among service technicians, may have an adverse effect on the polymer strip sensor’s continued functionality. SWRCB staff does not recommend cleansing se nsors with white gas unless specifically instructed to do so by the sensor manufacturer.November, 2000

Appendix I, Phase I Testing Summary Page 4 of 9



### SWRCB staff did not always witness testing in Sa nta Ana. Additionally, we were still refining the scope of data to be collected, testing proced ures, and protocol for da ta collection. For these reasons, results of testing in Santa Ana were usually considered only when making general observations and conclusions in this report , not in making any specific calculations. An exception to this is test data for model 794380-341 se nsors. Santa Ana test data for this model

has been included in the calculati ons of this report, since the sa mple size in Santa Monica and Oakland was so small. The local agency inspector present at all Santa Ana sites furnished us with his reports on the sites equipped with m odel 794380-341 sensors, and this data was used in calculating pass/fail rates for that model.

City of Oakland and City of Santa Monica Testing was conducted in Oakland and Santa Monica in October and November 2000. Local agency inspectors, Veeder-Root personnel, service technicians, and SWRCB staff were present

at all facilities tested. SWRCB st aff recorded all test data. U pon completion of testing, the data collected from Oakland and Santa Monica was comp iled in a data table, which is summarized in

Table III.

Table II - Summary of Veeder-Root Test Data from Santa Ana*

Dates of Testing August 21 st –25 th , 2000

Number of Facilities Tested 8

Number of Sensors Tested (model 794380-208) = 18
(model 794380-320) = 3
(model 794380-341) = 13
(model 794380-350) = 26
(model 794380-352) = 5
(model 794380-362) = 1
(model 794380-40x) = 10

Total Number of Sensors Tested 76

*Detailed test information not available for Santa Ana facilities


### Table III - Summary of Test Data from Oakland and Santa Monica

Number of Facilities Tested 18

Number of Sensors Tested (model 794380-320) = 2
(model 794380-322) = 1
(model 794380-341) = 6
(model 794380-350) = 8
(model 794380-352) = 49
(model 794380-360) = 1

Total Number of Sensors Tested 67

Pass/Fail Data for Model 794380-341 4 passes, 2 failures

Range of Response Times in Fuel and Fuel/Water Mix (794380-350) 3:26 to 42:50 (min:sec)

Range of Recovery Times in Fuel and Fuel/Water Mix (794380-350) 19:49 to 70:40 (min:sec)

Range of Response Times in Water (794380-352) 2 to 18 seconds

Average Response Time in Water (794380-352) 8 seconds

Range of Response Times in Fuel and Fuel/Water Mix (794380-352) 4:59 to 12:10 (min:sec)

Average Response Time in Fuel and Fuel/Water Mix (794380-352) 7 minutes, 15 seconds

Range of Recovery Times in Fuel and Fuel/Water Mix (794380-352) 0:27 to 52:29 (min:sec)

Average Recovery Time in Fuel and Fuel/Water Mix (794380-352) 17 minutes, 26 secondsNovember, 2000

Appendix I, Phase I Testing Summary Page 5 of 9



### Discussion Since the operating mechanism and testing procedure of the Veeder-Root model 794380-341

sensor are different than all the other sensors in our study, it is reasonable to divide the “discussion” section into two parts: one pa rt for the 794380-341 (ultrasonic mechanism), and one for all of the other sensors in our study (polymer-strip mechanism).

Ultrasonic Mechanism (V eeder-Root Model 794380-341)

Our testing showed the 794380-341 interstitial fiberglass tank sens or performed unsatisfactorily.

Eleven of 20 model 794380-341 sensors fa iled when tested in the field 2 

### . Usually, the sensors detected the presence of liquid, but were unable to discriminate between fuel and water. VeederRoot determined the failures are due to a faulty solder joint within the sensor, and is planning to make design changes to eliminate the problem. Since the sensor cannot reliably discriminate between fuel and water, Veeder-Root intends to reclassify the current 794380-341 sensor as nondiscriminating 3



### .

When testing the 794380-341 sensors in Santa Ana, we observed that they often came out of the tanks wet. The moisture was a clear, odorless a nd somewhat gooey film. When the film dried, it became milky white 4 

### . There appeared to be moisture in th e interstitial spaces of the tanks these sensors are monitoring, but not enough to activate an alarm. Follow-up information from Santa

Ana indicates that these sensors had to be cleaned before they would alarm properly when tested,

and that this is a common occurrence observed by inspectors during routine sensor field

certifications.

Polymer-Strip Mechanism (Veede r-Root Models 794380-320, 794380-322, 794380-350, 794380-352, 794380-360, 794380-361, and 794380-362)

The polymer-strip discriminating sensors consist of three separate sensing elements. The low and high liquid detectors are floa t switches or ultrasonic sensors depending on the model. The product-sensing element is a polymer strip that absorbs hydrocarbons. The strip is imbedded with small particles of conductive material (S ee Figure II). As the strip absorbs hydrocarbons, the material expands and the strip becomes less conductive (e.g. the resistance rises). When the

resistance reaches a certain leve l (for Veeder-Root sensors this is set at approximately 250 k Ω to

500 k Ω ) an alarm is activated.

2 Includes data supplied by the local agency inspector present at Santa Ana test sites.

3 Veeder-Root has completed reclassification of the mode l 794380-341 sensor since this summary was originally prepared.

4 The local agency inspector present at these facilities was concerned that the liquid may include resin or adhesive used in construction of the fiberglass tanks where these sensors are installed. Figure II – Polymer strip used in discriminating sensorsNovember, 2000

Appendix I, Phase I Testing Summary Page 6 of 9



### The low and high-level liquid sensors proved to be generally effective. They typically activated a liquid alarm in less than the third-party specifie d time. On the few occasions that a sensor did not respond properly, the problem was usually diagnosed as faulty wiring or improper programming of the console and not a design problem.

While our field-testing showed the low and high level liquid sensors to be effective, several issues concerning the polymer strip were raised which may be cause for concern and further investigation. Other issues, such as control pane l configuration and testing protocols, were also brought to light in the course of field-testing. The following pa ragraphs discuss these concerns

in detail.

1. Response and recovery times of the polymer strip element when exposed to fuel were sometimes excessive, and not always consistent with third-party claims. Primary concerns include the length and variation of response and recovery times, as discussed below:

(a) Length of Response Times

The fuel alarm is activated only after e nough fuel has permeated the polymer strip to

raise its electrical resi stance to a value of 250 k Σ -500 k Σ . The time required to reach the necessary electrical resistance varied from 5 to 12 minutes, with an average of just above 7 minutes. Typically the resistance in the strip did not change a ppreciably for several minutes. In the event of a catastrophic lea k, this response time could lead to large amounts of fuel in the dispenser pan or co ntainment sump. As the liquid level reaches the high-level liquid sensor a high level wa ter alarm will sound, but it could still be many minutes before the polymer strip reacts to the fu el and activates a fuel alarm. This would be a major concern if the system is not c onfigured for turbine shutdown when the high

level water alarm is activated.

(b) Variation of Response Times

With the wide variation in response times between sensors of the same model tested in the same product, it is difficult to say ex actly how long a polymer-strip sensor should typically take to alarm once exposed to fuel . This makes it difficult to establish fieldtesting guidelines, or to determine if a sensor is actual ly non-functional or just slow to respond.

(c) Length of Recovery Times

Recovery times often exceeded the third-pa rty value of 17.17 minutes. Values ranged from under 1 minute to over 52 minutes, with an average of more than 17 minutes. Like a sponge in water, the strip swells when exposed to fuel. It must completely dry out and return to its original shape in order to come out of alarm. This can take quite awhile, depending on how saturated the st rip is and how volatile the li quid is. In the interest of time, our test procedure called for a minimum amount of fuel, and for the sensor to be

removed from fuel as soon as it alarmed. We even experimented with removing the

sensor from fuel before it had alarmed in hopes of decreasing recovery times. Even so, the recovery times were high. Although the test protocol used in this study did not include long-term immersion of sensors in fuel, it is reasona ble to believe that sensors immersed in fuel for extended periods of tim e (as would be the case in the event of an actual leak) would take ev en longer to recover, or may not recover at all.November, 2000

Appendix I, Phase I Testing Summary Page 7 of 9



### 2. Response and recovery times seem to vary with weather conditions. (a) Warm and dry vs. cool and wet conditions Although it is difficult to substantiate with hard data due to the inconsistency of our testing procedures 5 

### , the polymer strips tended to re spond and recover more quickly in

warmer weather. We observed that sensors tested in the sun and sensors tested during dry conditions recovered more quickly than se nsors tested in rai ny or colder weather. This may be due to the fact that in colder or more humid weather fuel is less volatile.

(b) Very cold conditions The correlation between temperature and re sponse/recovery time may become a major factor at extremely low temperatures. In ou r field evaluation, we di d not test sensors in freezing conditions, so we do not know if the po lymer strips are sti ll effective at these temperatures. Is fuel volatile enough during freezing temperatures for the sensor to absorb the hydrocarbons and go into alarm? We posed this question to Veeder-Root in a letter. Nowhere in the third-party evaluati on is temperature or humidity considered. We simply do not know how effective these sens ors will be in extreme temperatures.

In addition to the polymer strips, we are also concerned about the f unctionality of float switches in freezing conditions , especially those monitori ng shallow sumps and shallow under-dispenser containment boxes. It may be possible for condensation to freeze on a float switch and render it inoperable.

3. The frequency of data transmittal between the se nsor and the control console is a factor in response and recovery times.

The console (e.g., TLS 350) “looks” at the status of each sensor or leak detection element in the UST system. It cycles through each sensor and element in the system before returning to the beginning. If multiple sensors and elements are built into the programming, it may take more time for the console to return to a particular sensor. As a result, facilities with a large number of sensors may take longe r to activate an alarm at the

console than those with a small number of sensors.

4. Alarm Settings and Pump Shutdown Features.

Many of Veeder-Root’s polymer-strip discrimi nating sensors have th ree different types of alarms: a low liquid alarm, a high liquid alarm, and a fuel alarm.

• The low liquid alarm is triggered by a float switch or ultrasonic mechanism located at or near the bottom of the sensor housing. This mechanism will “trip”

whenever it is covered with fluid. It does not discriminate between water and

fuel. This mechanism activates a warni ng (yellow light) at the control panel.

• The high liquid alarm is also triggere d by a float switch or an ultrasonic mechanism, which is located a few inches from the top of the sensor housing.

5 In warm weather, the thin layer of fuel used on top of wa ter evaporated completely befo re the sensor alarmed. The service person conducting the test had to add more fuel several minutes into the testing, causing very long response

times. Therefore the correlation betw een temperature and response time which might otherwise have been evident is not readily recognized.November, 2000

Appendix I, Phase I Testing Summary Page 8 of 9 

### Again, this mechanism cannot discrimi nate between water and fuel. This mechanism activates an alarm (red light) at the control panel.

• A fuel alarm is triggered by a polymer st rip that runs the length of the sensor housing, from the bottom of the sensor to the top float switch. Unless the polymer strip detects hydrocarbons, alarms from this mechanism are considered an

indication of water intrusion. This mechan ism activates an alarm (red light) at the control panel.

Both warnings and alarms are designed to al ert the operator that there is something wrong with the UST system. Each requires invest igation, and should re ceive an appropriate response from the operator. Warnings and alarms may also be programmed to activate pump shut-down, which turns off the turbine so that the UST cannot operate. Pump shutdown is generally only done with alarms.

If warnings or alarms are ignored and the li quid level exceeds the height of the top float switch, the sensor no longer detects additiona l fuel or water entering the sump. The sensor becomes ineffective and no longer prov ides leak detection; therefore, pump shut down at the high level alarm is a must.

5. High Vapor Mode

Another feature of the Veed er-Root control panel is th e “High Vapor Mode.” This operating mode is designed for use in ar eas where background levels of hydrocarbon vapors are high enough to activate the fuel alarm, even though the UST system is not leaking. This may be due to a previous rele ase of product, or possibly the materials and

adhesives used in the construction of the UST itself may release vapors. “High Vapor

Mode” is a tool used to eliminate false alarms . When the console is configured in “High Vapor Mode,” the sensor will not sound a fuel alarm unless it detects both the presence of liquid and hydrocarbons. The lo w liquid alarm mechanism mu st be triggered and the resistance in the polymer strip must be high enough to trigger a fuel alarm.

Although the sensors we tested in “High Vapo r Mode” seemed to be generally effective, they have not been third-party certified fo r operation in “High Vapor Mode” versus “Low Vapor Mode.”

6. Lack of Field Testing Procedures.

Although each manufacturer may provide its own manual of procedures for testing discriminating sensors, there are several di fferent tests a technician can run. Some agencies require a test of the low and hi gh liquid alarms only. Some agencies require testing the sensors in fuel a nd water separately. And some agencies require each sensor to be tested in fuel, in wate r, and in a fuel/water mixture.

Based on the results of our field testing, we de termined that it is necessary to periodically test all sensors in fuel. Even though the c onsoles are designed to run diagnostics on the sensors, the consoles do not always recognize problems with sensors or their wiring. We

encountered two or three sensors that were either not programmed properly or had wiring problems. These programming or wiring problems were only discovered throughNovember, 2000

Appendix I, Phase I Testing Summary Page 9 of 9 

### physical testing of the sensors in fuel. We might also benefit from testing sensors in a water/product mixture, since it simulates more accurately conditions encountered in parts of the UST system that ar e prone to water intrusion.

7. Degradation of Polymer Strips

Our testing provided no conclusive information as to the long-term re liability of polymerstrip sensors in harsh environments, or after repeated/prolonged exposure to hydrocarbons. Results of testing showed a wi de variation in the response and recovery times for the polymer strip sensors. In many cases these times exceeded the third-party specifications.

The manufacturers of polymer strips claim th e strips are testable and reusable, but each time the strip comes in contact with fuel, it apparently either retains some of the volatile compounds within its material or its elastic ity is compromised af ter repeated/prolonged hydrocarbon exposure. Once exposed to fuel, the sensor is no longer “good as new.” Eventually, the sensor will degrade so much th at either it may not recover from an alarm condition (the resistance will not drop to the poi nt that it comes out of alarm), or the probability of false alarms will be very hi gh. We do not know how many testing cycles a sensor can reasonably accommodate.

8. Volatility of Stored Product

The polymer strip is most readily activat ed by volatile hydrocarbons, with unleaded fuel and white gas producing the most rapid res ponses. The sensors also recovered from exposure to these fuels fairly consistently. Diesel fuel would activate an alarm, but not nearly as quickly as the more volatile unlead ed fuel. Recovery times were very slow. Veeder-Root suggested cleaning se nsors exposed to diesel fuel with white gas in order to speed up recovery. Technicians told us that sensors exposed to diesel must often be airdried for days, and even then, sometimes never recover.

Although we encountered some waste oil UST systems being monitored by Veeder-Root discriminating sensors, we did not test the se nsors in waste oil. Veeder-Root’s sensors are not third-party evaluated for use in waste oil applicat ions. We are concerned that waste oil may not be volatile enough to tri gger an alarm from polymer strip sensors.

9. Third-Party Protocol is Inappropr iate for Polymer Strip Sensors

Third-party testers have been using standard liquid point detection protocols to evaluate the polymer-strip sensors. These protocol s are usually designed for mechanical or electrical switching devices th at do not use chemical reactions like the polymer strips. It may be necessary to develop a protocol th at takes into account the unique aspects of polymer-strip sensors. Ability to alarm and recover in a variety of environmental conditions should be assessed. The impact of repeated exposure of these sensors to fuel on response time and recovery time should also be evaluated.APPENDIX IIWorkplan for Phase II of the Field EvaluationAppendix II, Workplan Page 1 of 1 

## SWRCB Sensor Field Evaluation Wo rkplan (Phase II) – July 3, 2001

Team Members Project Supervisor: Shahla Farahnak, P.E. Project Coordinator: Scott Bacon

Assistant Coordinator: Raed Mahdi Field Testing Staff: Raul Barba, Eric Luong, and Jennifer Redmond



### Purpose of the Project This project is intended to evalua te the functionality of liquid and vapor sensors used to monitor UST systems. The focus will be on “real world” effectiv eness, with testing performed at operating facilities where the sensors are currently inst alled. The study is designed to:

• Evaluate the functionality of sensors used in California;

• Check the adequacy of field-testing procedur es for sensors (or work with manufacturers to develop field-testing procedures if they are not already available);

• Determine if sensors in the field perform consis tently with the specifications outlined in their third-party evaluations; and

• Determine if the third-party eval uation protocol currently used is suitable for each of the sensor types evaluated with that protocol.



### Coordinating Field Efforts In order for us to test at a UST facility, several people must be present or notified. At a minimum, this

will include SWRCB staff and a service technician on site, as well as notification of the facility owner/operator. Additionally, local agency insp ectors and sensor manufacturers may be present. We plan to work with local agencies and maintenance contractors to coincide our testing with the required annual maintenance inspections already scheduled at the facilities



### Data Collection Process

• Field Testing Method – Experienced service technicians will conduct the testing. They will access sensors in sumps, tank interstice, dispenser pans, excavation linings, and monitoring wells. The sensors will be immersed in water at a dept h corresponding to their third-party evaluation. In addition, discriminating sensors will be tested in fuel and/or a fuel/water mixture.

• Data Recording – Our staff will observe the testing and record data. We will record sensor response and recovery time, as well as inform ation about the sensor make, model, and application. Additionally, we will record data about the facility and the condition of the area the sensor is located in. Through careful collection and analysis of data, we hope to determine what factors may adversely effect sensor performance.

• Industry Professional’s Survey
- In addition to the data collected from field-testing, we will survey experienced maintenance technicians and inspectors. Their responses will be used to supplement our field data and give us a clearer picture of sensor effectiveness.



### Safety Considerations Qualified contractors will perform all hands-on testing. They have been trained to safely deal with the equipment and hazardous substances found at the faciliti es where our testing will take place. Our staff will only observe and record data, but all applicable st andards of safety will be adhered to. This includes, but is not limited to, proper securing of the work area from traffic hazards.



### Final Report/Summary A thorough report will be completed at the end of fiel d-testing. It will detail our testing activities and present the data collected from both the tests and comp leted surveys. In addition, the report will state

conclusions and recommendations based on the results of our study.APPENDIX IIILocation of Facilities Included in the Field EvaluationApp e n d i x III, Lo cation o f facilit ies in clu d e d in th e field evalu a tio n Pag e 1 o f 1 

# Location of Facilities Included in the Field Evaluation of Underground Storage Tank System Leak Detection SensorsAPPENDIX IVField Data Collection FormsAppendix IV, Field Data Collection Forms Page 1 of 3 

# SWRCB SENSOR FIELD EVALUATION

SITE DATA COLLECTION FORM

Site # ________________________

SITE INFORMATION

Date: Time Testing Begins: Time Testing Ends: Facility Name: Address: Major Oil Independent Oil Government Agency Facility Ownership:

Other:

Tank Type: Single-Wall Double-Wall Steel Fiberglass Dry Hydrostatic

Piping Type: Single-Wall Double-Wall Pressurized Suction

Steel Fiberglass Flex Fiber Trench

# of Tanks: # of Sumps: # of Dispensers:

STAFF

SWRCB Staff Present: Local Agency Staff

Present Agency:

Service Technician(s) Conducting Test:

Contractor: Years in Industry:

Manufacturer’s Representatives: Manufacturer:

WEATHER CONDITIONS Temperature at Start of Testing: Temperature at End of Testing: Humidity at Start of Testing: Humidity at End of Testing:
Sunny Cloudy Windy Light Rain General

Conditions: Heavy Rain Fog Other:

COMMENTS:Appendix IV, Field Data Collection Forms Page 2 of 3 

## SWRCB SENSOR FIELD EVALUATION, SENSOR DATA COLLECTION FORM

EQUIPMEMNT INFORMATION

Sensor Make: Sensor Model:

Sensor Serial #: Sensor Manufacture Date:

Control Panel Make: Control Panel Model:

Control Panel Serial #: Control Panel

Manufacture Date:

Float Switch Ultrasonic Product Permeable Optical Operating Principle:
Capacitance Change Product Soluble Thermal Conductivity Conductivity Discriminating? Y N Continuous? Y N Reusable? Y N Listed in LG-113? Y N

APPLICATION INFORMATION

Tank Interstice Pump Sump Fill Sump UDC Sensor Location:
Vapor Well Groundwater Well Trench Liner

Is Sensor at Lowest Point?

Yes No NA Is Wiring Connected Properly?

Yes No NA Total # of Sensors

Recorded on this Form: Is Clean and Dry Contains Water Contains Debris Brine-Filled Sensor Location... (check all that apply) Contains Product Contains Backfill Has Strong Vapor Smell Regular Unleaded Mid-Grade Unleaded Premium Unleaded Water Sensor is Monitoring for

the Presence of... Diesel Brine Waste Oil Other:

Steel PVC/Plastic Fiberglass Tank/Sump/UDC Monitored by Sensor is... Membrane/Liner HDPE Other:
Tank/Sump/UDC Manufacturer:

WATER TEST (Low)

Water Height: Response Time Recovery Time Pump Shut-Down Yes No NA

Alarm Activated: Water Product Both None Test Result: Pass Fail

WATER TEST (High)

Water Height: Response Time Recovery Time Pump Shut-Down Yes No NA

Alarm Activated: Water Product Both None Test Result: Pass Fail

PRODUCT TEST Product Used:

Product Height: Response Time Recovery Time: Pump Shut-Down Yes No NA

Alarm Activated: Water Product Both None Test Result: Pass Fail

PRODUCT ON WATER TEST

Water Height: Product Thickness: Response Time: Recovery Time:

Alarm Activated: Water Product Both None Pump Shut-Down Yes No NA

Product Used: Test Result: Pass Fail

After testing this sensor was: Repaired 1 Replaced Re-Tested 2 Re-Installed



## COMMENTS:

1 Describe repairs in Comments section

2 If the sensor is re-tested, record test data in anot her sensor form and attach it to the back of this form1)Sensor Location: T1 to T4 are sensors in tanks 1-4, S1 to S4are sensors in the turbine sumps of tanks 1-4, additional sensorlocations should be included in the“comments” section of this form.2)Alarm Type: W = Water, F = Fuel, N = None. Include both W and F if applicable.3)Times: All times will be taken from the moment the sensor isplaced in the fluid. The clockwill not be zeroed between alarmactivation and recovery.4)Indicate any sensors that were replaced, noting the model # of the old and new sensors as well as the reason for replacement.Appendix IV, Field Data Collection FormsPage 3 of 3Veeder-Root Discriminating Sensor Field Performance TestSite Address:Date:TestingContractor:SWRCB Staff:Weather Conditions:Diameter of test apparatus(in.):Site ID #:High Water LevelFuelWater/Fuel MixtureResponseResponseResponseRecoveryTime(mm:ss)SensorModelWaterLevel(in.)Time toAlarm(mm:ss)AlarmType(WFN)RecoveryTime(mm:ss)FuelLevel(in)Time inFuel(mm:ss)Time toAlarm(mm:ss)AlarmType(WFN)RecoveryTime(mm:ss)WaterLevel(in.)FuelThickness(in.)Time inLiquid(mm:ss)Time toAlarm(mm:ss)AlarmType(WFN)PassOrFail?S1S2S3S4T1T2T3T4Comments:APPENDIX VSensor Survey Distribution Letter, Survey Form, Results, and Comments

# State Water Resources Control Board

Division of Clean Water Programs

1001 I Street • Sacramento, California 95814 • (916) 341-5871 Mailing Address: P.O. Box 944212 • Sacramento, California • 94244-2120 FAX (916) 341-5808 • Internet A ddress: http://www.swrcb.ca.gov



### California Environmental Protection Agency

Recycled Paper Winston H. Hickox Secretary for

Environmental

Protection Gray Davis

Governor



### October 24, 2001

TO: Interested Parties

SURVEY FORM FOR SENSOR FIELD STUDY

We are sending this letter to you, as someone who ma y have expertise in the performance of the various sensors used in UST systems. We are concerne d about the performance of these sensors, specifically those in tank-top sumps, tank annular spaces, and under dispenser containment. As you know, their performance is critical in detecting leaks. Therefore, we have initiated our own study to evaluate their effectiveness under actual operating conditions.

We plan to visit 200 operating UST facilities and co llect data on sensor performance. However, we recognize that our field study is limited and would be incomplete without input from those who have valuable first-hand experience with these sensors. Therefore, we are requesting your assistance to complete the enclosed survey form and return it to us. This will a llow us to incorporate your knowledge and experience into our study. We estimate it will ta ke approximately 30 minutes to complete the entire survey, however we are interested in your views even if you can only complete a portion.

Please distribute the survey to anyone in your organi zation who routinely works with UST leak detection sensors. This includes, but is not limited to, service t echnicians, inspectors, installers, and environmental managers. Please return the completed surveys by November 15, 2001 to:

Attention: Scott Bacon

State Water Resources Control Board Department of Clean Water Program

P.O. Box 944212 Sacramento, CA 94244-2120 Fax: (916) 341-5808

If you prefer, you may complete and submit the survey online at: http://www.calcupa.net/support/index.htm

If you have any questions regarding this survey, please contact Scott Bacon at (916) 341-5873 or email: bacons@cwp.swrcb.ca.gov.

Sincerely,

- ORIGINAL SIGNED BY -

Shahla Dargahi Farahnak, P.E., Chief Engineering Unit 2 Underground Storage Tank Program

EnclosureAppendix V, Survey Page 1 of 3 

## UST SENSOR STUDY SURVEY

STATE WATER RESOURCES CONTROL BOARD (Please answer all the questions that are applicable based on your experience in the field)

Information provided by: – (Leave blank if you prefer to submit this survey anonymously)

Name: _________________________________ Company/Agency: _____________________________ Address: _______________________________________________ Telephone: ____________________



### GENERAL INFORMATION

1. What is your affiliation? Local Agency Inspector Technician Consultant Owner/Operator Other ( Specify)

_______________________

2. How many years of experience do you have in the UST field? ___________



### 3. Average number of UST facilities you inspect/service monthly? _______ Not applicable



### OVERALL SENSOR INFORMATION

4. Do you perform/require a functional test (i.e. accessi ng the sensors and activating an alarm by flipping them over, immersing them in liquid, etc.) of all sensors during the annual UST monitoring equipment

certification? Yes No

5. What percentage of the sensors you encounter in the field are failing the functional tests?

<5% 5-10% 10-20% 20-30% 30-40% 40-50% >50%

6. What percentage of the sensor failu res are due to the following factors:

a) Poor design: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% b) Installation: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% c) Maintenance: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% d) Programming: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% e) Tampering: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% f) Other: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50%

7. Sensor failure is most common in: Steel Tanks Dry Interstice Fiberglass Tank

Wet Interstice Fiberglass Tank Tank-Top (pump/fill) Sumps Under Dispenser Containment Location is not a factor in sensor failureAppendix V, Survey Page 2 of 3 

### SENSOR COMPARISON

8. Please complete this section to the best of your knowledge:

Float

switch Polymer strip Optical Prism Ultrasonic Conductivity Capacitance change

% failure rate

* Indicate most common reason(s)

for failure

*Failure Reasons: P = Programming M = Maintenance I = Installation T = Tampering PD = Poor Design Other = Please indicate

9. What specific make(s) and/or model(s) of sensor are most reliable? _____________________________

_______________________________________________________________________________________

10. What specific make(s) and/or model(s) of sensor are least reliable? ______________________________

_______________________________________________________________________________________



### DISCRIMINATING SENSORS

11. What percentage of the sensors you use /inspect/service are discriminating sensors?

- Tank Interstice: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% - Turbine Sumps: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50% - Under Dispenser: <5% 5-10% 10-20% 20-30% 30-40% 40-50% >50%

12. Based on your experience, discriminating senso rs are ________________ when compared to nondiscriminating sensors?

More reliable Less reliable Equally reliable

13. For discriminating sensors using polymer strip, what is the typical time for each of the following?

a) response in unleaded fuel:

<30sec 30-60sec 1-3min 3-5min 5-10min 10-20min >20min

b) recovery in unleaded fuel:

<1min 1-3min 3-5min 5-10min 10-20min >20min Not reusable

c) response in diesel fuel:

<30sec 30-60sec 1-3min 3-5min 5-10min 10-20min >20min

d) recovery in diesel fuel:

<1min 1-5min 5-15min 15-30min 30-60min >60min Not reusableAppendix V, Survey Page 3 of 3 

### 14. Is there a change in response times for polymer strip sensors after repeated exposure to fuel?

Response time for polymer-strip sensors increases after repeated exposure to hydrocarbons. Response time for polymer-strip sensors decreases after repeated exposure to hydrocarbons. Response time for polymer strip sensors does not change after repeated exposure to hydrocarbons.



### 15. Which of the following methods do you most often u se/require when testing discriminating sensors?

Test in water only Test in product only Test in both product and water Flip sensor over I do not test/require testing of discriminating sensors



### PUMP SHUT-DOWN FEATURE

16. What is the typical time delay between sensor activation and pump shut-down?

<5sec 5-10sec 10-30sec 30-45sec 45-60sec 1-2min >2min

17. For sensors programmed for pump shut-down, wh at percent of them shut down the pump?

<5% 5-10% 10-20% 20-30% 30-40% 40-50% >50

18. What are the most common reason(s) for failure of the pump shut-down?

Programming Maintenance Installation Tampering Relay box (Equipment problems) Other (Specify) __________________



### ADDITIONAL INFORMATION

19. What changes can be made to improve sen sor reliability?_________

______________ _______________

____________________________________________________________________________________

____________________________________________________________________________________

___________________ __________________ _________________ _______________ _______________

____________________________________________________________________________________

20. Do you have any other comments you would like to share with us? _____________________________

____________________________________________________________________________________

____________________________________________________________________________________

____________________________________________________________________________________

___________________ __________________ __________________________ ____________ _________Number of UST Facilities Inspected/Serviced by Respondent

0

0.5 1 2 3 4 5 6 7 8 10 12 15 20 25 30 35 50 60
UST Facilities per MonthResponses Experience of Survey Respondents

0

0.5 1 2 3 4 5 6 7 9 10 11 12 13 15 17 20 21 30
Years ExperienceResponses 

### ABOUT THE RESPONDENTS 

# SWRCB Sensor Field Evaluation, Survey Results

71 local agency inspectors and service technicians responded to the survey. The following tables summarize their responses to a variety of questions on UST leak detection sensors.

1 4 12

10

6

5

1 2

1 6

1 3 4

3

1 1 1 1 2 4 6 8 10 12 14

1 3 4

2 3 6

5 5

1 7

5 8

2 9

1 2

1 1 1 2 3 4 5 6 7 8 9 10

Appendix V, Survey Results Page 1 of 6Do you Require Functional Test of Sensors? Percentage of Sensors Failing Functional Test

< 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% 1 64

Responses 33 16 10 4 0 2 0

0 5 10 15 20 25 30

What Percentage of Sensor Failures are Due to

Poor Design?

21 8 2 3 3 2 6

Responses Responses No Yes

0 10 20 30 40 50

0 2 4 6 8 10 12 14 16 18 20 22 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% What Percentage of Sensor Failures are Due to

Poor Installation?

18 7 6 4 2 1 5

Responses 0 2 4 6 8 10 12 14 16 18 20 22 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50%

35 60 70PercentagePercentagePercentage

Appendix V, Survey Results Page 2 of 6 

### GENERAL SENSOR INFORMATIONLocation Where Sensor Failure is Most Common

Dry Interstice Fiberglass Tank Location is not a factor in sensor failure

Steel Tanks Tank-Top (pump/fill)

Sumps Under Dispenser Containment

< 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% What Percentage of Sensor Failures are Due to Tampering?

13 4 3 2 0 1 1

Responses 0 2 4 6 8 10 12 14 16 18 20 22 15 21 1 16 2

Responses 0 2 4 6 8 10 12 14 16 18 20 22 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% What Percentage of Sensor Failures are Due to

Poor Maintenance?

15 8 6 5 2 4 1

Responses 0 2 4 6 8 10 12 14 16 18 20 22 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% What Percentage of Sensor Failures are Due to

Improper Programming?

14 13 4 6 1 3 2

Responses 0 2 4 6 8 10 12 14 16 18 20 22PercentagePercentagePercentage

Appendix V, Survey Results Page 3 of 6Equally Reliable Less Reliable More Reliable Reliability of Discriminating Sensors

as Compared to Non-Discriminating

10 41 2

Responses 0 5 10 15 20 25 30 35 40 45 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% Percentage of Discriminating Sensors in Tank Interstice

39 6 4 5 3 1 0

Responses 0 5 10 15 20 25 30 35 40 < 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% Percentage of Discriminating Sensors in Turbine Sumps

28 8 7 7 4 1 4

Responses 0 5 10 15 20 25 30 35 40

< 5% 5 to 10% 10 to 20% 20 to 30% 30 to 40% 40 to 50% > 50% Percentage of Discriminating Sensors in UDC

29 10 6 4 4 1 3

Responses 0 5 10 15 20 25 30 35 40PercentagePercentagePercentage

Appendix V, Survey Results Page 4 of 6 

### DISCRIMINATING SENSOR INFORMATIONDiscriminating Sensor Response Time in Unleaded Fuel

4 6 9 4 7 2 3

Responses Discriminating Sensor Recovery Time in Unleaded Fuel

1 5 2 4 10 9 3

0 2 4 6 8 10 12 < 1 min 3 to 5 mins 10 to 20 mins not reusable

Discriminating Sensor Response Time in Diesel Fuel

2 6

4 2 3 4 10

< 30 secs 30 to 60 secs 1 to 3 mins 3 to 5 mins 5 to 10 mins 10 to 20 mins > 20 mins

Responses Discriminating Sensor Recovery T ime in Diesel Fuel

1 3 0 0 3 11 6TimeTimeTimeTime 1 to 3 mins 5 to 10 mins > 20 mins

Responses

0 2 4 6 8 10 12

Responses < 1 min 3 to 5 mins 10 to 20 mins not reusable

1 to 3 mins 5 to 10 mins > 20 mins

0 2 4 6 8 10 12 < 30 secs 30 to 60 secs 1 to 3 mins 3 to 5 mins 5 to 10 mins 10 to 20 mins > 20 mins

0 2 4 6 8 10 12

Appendix V, Survey Results Page 5 of 6Installation Maintenance Programming Relay Box Tampering

Other How are Discriminating Sensor Being Tested ?

8 21 10 9

0 5 10 15 20 25 Flip Sensor Over Test in Product Only

Pump Shut-Down Delay Time

12 16 19 11 4 2 1

< 5 secs 5 to 10 secs 1 to 2 mins > 2 mins

Responses Reason for Failure of Pump Shutdown

2 8 11 28

8 3Time Test in Both Product and Water

Test in Water Only

Responses

0 5 10 15 20 25 30

Responses 0 5 10 15 20 Changes in Response Time for Polymer Strips After

Repeated Exposure to Fuel

14 11 7

Responses 0 2 4 6 8 10 12 14 16 increases decreases does not change

10 to 30 secs 30 to 45 secs 45 to 60 secs

Appendix V, Survey Results Page 6 of 6 

### PUMP SHUT-DOWN INFORMATIONAppendix V, Survey Comments and Recommendations page 1 of 3 

## Online Survey Comments and Recomm endations for the Sensor Field Evaluation of Underground Storage Tanks:

This is a compilation of comments and recommendati ons we received from our survey participants. These comments represent the views of the participants surveyed and may not reflect the opinions of the SWRCB.

• Discriminating sensors must be able to be tested in the actual product and must clear within a few

minutes.

• Improve maintenance of sensors and replace outdated ones.

• The polymer strip type sensor appears to be a poor design for immediate identification of a leak. Remove this type from the approval list.

• Do not allow the use of sensors associated with the MSA Tankguard. I'm not sure, but I believe that they are polymer strip discriminating sensors. They have an extremely low response and recovery time of about 15-20 minutes. Also the sensitivity of th e MSA Tankguard can be ad justed and always seems to need to be adjusted at each inspection. The al arm may not sound when the sensor is being tested in liquid, but then sound when it is not being tested. I do not trust the reliability of these sensors.

• Operator training, proper maintenance and tamper proofing.

• Eliminate discriminating sensors a ltogether in annular spaces. H eck, eliminate them everywhere. They are only good for sumps and containment areas that are so poorly constructed that liquid intrusion is a constant problem. Repairing the sumps would be a better solution to liquid intrusion problems.

• The positive shut down sump sensors are plastic and they stick open. Some type of new stick product

is needed.

• You might want to require that all sensors be replaced regularly every 2-3 years.

• Eliminate discriminating sensors unless they have <5sec-response time. They need to be designed so that corrosion and sticking do not occur. Needs to be such that maintenance is minimized since this is only done annually.

• Require quarterly maintenance and inspection of sensors.

• Make them simple and easy to place. The Tri-State feat ure is best on systems that have no maintenance

crew.

• Overall experience with discriminating sensors is minimal, but due to survey set cases/problems, we do not allow or will approve them for use in the city. Result is problematic.

• Better design, stronger materials, and no resistors at sensor end.

• Improve design on brands listed in question 10. Discriminating sensors are not practical. I do not test them due to recovery time. Sometimes they do not recover.

• I don't know if it is possible, but what if they made a sensor that was non-stick so that sludge would not hold the float, making it stuck. The contact points would also need to be sludge proof.

• Better installation practices. Sensors are not being hung at the correct location, i.e. at the bottom of the tank or sump.Appendix V, Survey Comments and Recommendations page 2 of 3 • Eliminate discriminating sensors or improve technology. Operate and test sensors under various simulated conditions. Improve technology of annular float sensors in FG tanks to improve accessibility/visual inspection/simulated testing.

• Be there at the annual maintenance checks. You learn a lot, see a lot of the important violations and disrupt the business only once. The entire focus of my inspections is the leak detection systems for piping and tanks. They must work. Operators do not like to do leak detection manually. Pushing toward all electronic monitoring is essential for the future. Get the operators out of it. Have the ATG print out the monthly .2 gph-passing test for tanks at least once a month automatically. Then the operator saves this record for the inspection.

• Testers hate to test the discriminating sensors with product because they know they will have problems getting them cleared, if at all. If the sensors won't clear, then it must be replaced, and tested. On one occasion, the technician did not have a discrimina ting sensor replacement with him so he had to call his shop and have someone drive one out to the site. This kept that product offline for several hours. The facility operator was not happy.

• Get rid of sacrificial sensors, and require secondary containment for all piping!!!

• My primary objective in completing this survey is to expose the problems that I have encountered in trying to test the sensors for the MSA Tankguard system. All other sensors that I have encountered are sufficiently reliable.

• The compatibility of simple contact switch sensors w ith the control panels is not a major issue or an operational problem. The use of discriminating sensors is a major issue even when these sensors are used with a compatible control panel.

• We hardly see discriminating sensors. The alarm n eeds to go through a central alarm system in which case we will know of any release. Tampering def eats the purpose of monitoring. We find improper positioning of the probe/ raised probe 80 % of the sites. Water intrusion a real problem.

• A tank system that is properly constructed and maintained should never have liquid intrusion problems and therefore there is no need for discriminating sensors.

• Owners need a good, simple manual on the tank system components, requirements, and responsibilities: like "straight talk on tanks" in more detail. So many stations change hands and so many employees are dueless, that comprehensive explanation of UST's is desperately needed to start to get an unformed constituency.

• Bravo box float mechanisms for dispenser containment monitoring were not mentioned in this survey

but have about a 50% failure rate due to debris or loose chains. SFSFD water tests all float monitored dispenser pans.

• Sensor reliability or rather the lack there of, has caused local agencies to all other leak detection and testing requirements to UST's. The confidence leve l in the sensors functioning properly at any given time is low, Because of this the confidence in our UST programs goal of preventing and detecting releases is also somewhat low. Why spend a lot of time and resources when the devices are unreliable? Also, this didn't address mechanical systems. The Bravo Float system has chronic problems with not functioning properly after more than a year. The float does not leave very much

room for sidewalls of channels so dirt freezes the movement. Tampering by loosening chains is extremely common. We dislike this design.

• Phasing out existing monitoring systems. I.e. pollulert, petrometer, leak-x, petrovend, etc. Notion

current LG-113 should be an eventu ally to start planning for now.Appendix V, Survey Comments and Recommendations page 3 of 3 • Discriminating sensors add approximately 10 min. pe r sensor for testing and returning to operability. That adds about 2 hours to a standard gas station monitoring certification inspection.

• Question 13(d)- recovery time for dies el fuel is greater than 60 minutes.

• Please remove discriminating sensors from approved method. They are not reliable and/or do not sense for reasonable system monitoring (if located in sump bottom with water in sump a full leak will not be detected if the water level is above the sensor). Qu estion 7-Sensor failure is most common in Tank Top (pump/fill) Sumps and Under Dispenser Containment.

• This survey should allow free-text answers. Some pick-list choices ar e inadequate. At the very least, there should be a "unknown" response.

• In the past when we arrived on site for an inspection, the maintenance contractor or operator may have already tested and replaced any faulty sensors. Th is will skew the data you collect from inspectors, indicating higher performance rates.

• People raising probes due to surf ace water infiltration via rain or st eam cleaning the parking lot, which violates many laws.



### • Alternate technologies should be available for positive shutdown, which do not rely on the relay boxes.APPENDIX VIField DataAppendix VI, Definitions and List of Acronyms Page 1 of 1 

# Sensor Field Data Tables

List of Acronyms

Acronym Meaning

MR Sensor is manually reset after an alarm

MSA Mine Safety Appliances

NA Not applicable to the sensor being tested

NP Not programmed for pump shut-down

NT Not tested

PSD Pump shut-down

Rec Recovery time (in seconds)
Resp Response time (in seconds)

UDC Under-dispenser containment

Unk Unknown. Data was unavailable



# List of Definitions

Term Definition Flip Test Sensor was tested by flipping it over Heights All liquid levels are reported in inches High Test High-level water testing

Low Test Low-level water testing. For single-level sensors tested in water, test data will be

recorded in this column

Product Sensor was tested in product

Site ID #200 The 67 sensors tested during Phase I (VeederRoot discriminating sensors) are included in

this database under Site ID# 200

Times All response and recovery times are reported

in secondsAPPENDIX VI, TABLE 1Summary of All FailuresTABLE 1 - Summary of All FailuresMake At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSDAlpha wireUnk Yes Fail NT92Yes NT NA NA NT NTNPRe-InstalledBeaudreau406 No NA NT82Yes NT NA NA NT NTNAUnk406 Yes NA Fail10Yes NA NA NA NT NTNARe-InstalledLed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.406 Yes NA Fail10Yes NA NA NA NT NTNARe-InstalledLed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.406 Yes NA Fail10Yes NA NA NA NT NTNARe-InstalledLed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.GilbarcoPA02591144000 Yes Fail NT28Yes NT NA NA NT NTNPReplacedSensors was replaced by contractor two days after the inspection.PA02592000000 Yes Fail NT28Yes NT NA NA NT NTNoReplacedSensors was replaced by contractor two days after the inspection and positive shut down was rewired.PA02592000000 Yes Fail NT28Yes NT NA NA NT NTNoReplacedSensors was replaced by contractor two days after the inspection and positive shut down was rewired.PA02592000010 No NT Pass98Yes Yes NA NA NT NTNTRe-Installed3-4 inches of water on both sides of sump (low spots of tank top).PA02592000010 No NT Pass98Yes Yes NA NA NT NTNTRe-Installed2-3 inches of water on both sides of sump (low spots of tank top).PA02592000010 Yes Fail NT24Yes NT NA NA NT NTNoRepairedRelay was stuck, so the PSD failed when tested. It passed when re-tested.InconTSP-ULS No NT NT16No NT Fail Yes NT NTNTRepairedSensor was turned off when technician conducted the test. Sensor appears to have been turned due to water in the UDC. After turning the sensor on, it passed.TSP-ULS No Pass NT35Yes NT NA NA NT NTYesRe-InstalledThe sump was full of diesel approximately 9 1/2 inches deep.The sensor was set at the top of the sump to avoid alarming.MalloryControlsPollulert MD 241RRA Yes NA NT92Yes NT NA NA Fail NoNAUnkSensor failed the test, but the company is out of business.So,owner might have to change the system. Inspector gave the ownertwo weeks to fix it or replace It.Page 1 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,Make At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSDMSATankgard 482607 No NA NT17No NT NA NA Fail YesNARepairedSensor initially turned off.Appears to have been turned off due to product in the sump. Sensor worked when turned on; sensornot at lowest point - about 8" above.Tankgard 482607 Yes NA NT17Yes NT NA NA Fail NoNAUnkHad to leave site before witnessing removal or re-installation of sensor.Red JacketLiquid Refraction Sensor No Pass NT20Yes NT NA NA NT NTYesRe-InstalledSensor has been pulled up due to high water in the fill/vapor sump.RonanLS-3 No Fail NT20Yes NT NA NA NT NTNoUnkSensor appears to be good during a continuity test, but appears not to be hooked up to the control panel.LS-3 Yes Fail NT47No NT NA NA NT NTYesRepairedSensor would not come out of alarm after testing. Pump would notcome on. Contractor repaired the facility. Problem was wiring inside the building, near the control panel.LS-3 Yes Fail NT20No NT NA NA NT NTNoUnkSensor appeared to be functional when technician tested for continuity, but did not activate an alarm at the panel. Tech suspects problem with wiring between sensor and panel.LS-3 Yes Fail NT32Yes NT NA NA NT NTNPRepairedFloat was stuck. Technician had to shake itto loosen it, then sensor went into alarm.LS-7 No Pass NT1Yes NT NA NA NT NTNPRe-InstalledThe sensor could not be taken out of the tank interstice;therefore the sensor was activated within the tank.UniversalLALS-1 Yes Fail NT94Yes NT NA NA NT NTNAUnkContractor waited for 2 minutes for the sensor to response, but never did. Sensor had to be replaced.LALS-1 Yes NA Fail95Yes No NA NA NT NTNAUnkSensor was not tested because it was stuck in the interstitial space.LAVS-1 Yes NA Fail94Yes No NA NA NT NTNAUnkVeeder-Root794380-208 No Fail NT85Yes NT NA NA NT NTNoReplacedThe contractor decided to stop testing the sensor after it failedto respond for more than 2 minutes and replace it with a newsensor.794380-208 No Fail NT10Yes NT NA NA NT NTNoRe-InstalledAlarm activated at the control panel, but no pump shutdown. (printer said pump shutdown occurred, but pump continued to run.Picture of sensor is site 7 #2.). Follow up was done on this site and Inspector confirmedthat the PSD is functioning properly.794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-InstalledFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)Page 2 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,Make At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSD794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-InstalledFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-InstalledFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-TestedSensor timed out & Technician had to go and re-set it to shut down the pump.794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-InstalledFill bucket was detached. Stick was in the product line (to prevent the flapper from shutting down the flow). Most of sensors timed out & Technician had to go and re-set it to shut down the pump.794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-TestedSensor timed out & Technician had to go and re-set it to shut down the pump.794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-TestedSensor timed out & Technician had to go and re-set it to shut down the pump.794380-208 No NT Pass91Yes Yes NA NA NT NTNTRe-TestedSensor timed out & Technician had to go and re-set it to shut down the pump.794380-208 No Pass NT42Yes NT NA NA NT NTNPRe-InstalledContains a substantial amount of water.794380-208 No Pass NT76Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT73Yes NT NA NA NT NTYesRe-InstalledSensor was raised about 4 inchesfrom the bottom of the sump.794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT33Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT79Yes NT NA NA NT NTYesRe-InstalledProduct is leaking out of the top of the turbine pump.794380-208 No Pass NT79Yes NT NA NA NT NTYesRe-InstalledProduct is leaking out of the top of the turbine pump.794380-208 No Pass NT79Yes NT NA NA NT NTYesRe-InstalledProduct is leaking out of the top of the turbine pump.794380-208 No Pass NT42Yes NT NA NA NT NTYesRe-InstalledThe sensor was not located at the lowest point inthe tank. Technician lowered it and activetd an alarm.Page 3 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,Make At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSD794380-208 No Pass NT76Yes NT NA NA NT NTNPRe-Installed794380-208 No Pass NT62Yes NT NA NA NT NTNPRe-Installed2-3 gallons of product in the sump. Sensor was raised above the product level. Sensor in pump sump was not programmed to shutdown pump.794380-208 No Pass NT62Yes NT NA NA NT NTNPRe-Installed2-3 gallons of product in the sump. Sensor was raised above the product level. Sensor in pump sump was not programmed to shutdown pump.794380-208 No Pass NT42Yes NT NA NA NT NTYesRe-Installed794380-208 No Pass NT85Yes NT NA NA NT NTYesRe-InstalledThere was a hole in the sump, approximately 1 1/2" diam. Electrical wiring below penetration lines. Hydrostatic test was performed to the highest penetration lines at 16 minutes per cycle.Test at 16 psi and fail if below12 psi. Fill sump is not clean..794380-208 No Pass NT10Yes NT NA NA NT NTYesRe-Installed2 sensors, 1 raised in sump and the other was a the lowest point. Both responded and activated pump shut off. Picture of sensor was taken.794380-208 Yes Fail NT88Yes NT NA NA NT NTNoReplacedTechnician waited for over 2 minutes, but sensor did not alarm.Finally inspector decided to call the test off and replace thesensor. Testing was done on the new sensor and it passed.794380-341 Unk NA Unk200Unk Unk NA NA Fail UnkNAUnk794380-341 Unk NA Unk200Unk Unk NA NA Fail UnkNAUnk794380-341 Yes NA NT19Yes NT NA NA Fail NoNAReplacedReplaced with same type of sensor.794380-341 Yes NA NT38Yes NT NA NA Fail NANAReplacedSensor was tested with both unleaded gasoline and waste oil. Bothcases, water alarms were observed. Sensor was not approved for use in waste oil. After testing, sensor was replaced and it passed the product test.794380-341 Yes NA Pass38Yes NA NA NA Fail NoNAReplacedSensor sets water alarm for product test. After testing the sensor was replaced and the new sensor was setting the right alarm.794380-341 Yes NA Pass38Yes NA NA NA Fail NoNAReplacedSensor sets water alarm for product test. After testing, sensor was replaced and the new sensor was setting the right alarm.794380-341 Yes NA Pass64Yes Yes NA NA Fail YesNAUnkDetected product as water. Since pump shuts down for product or water, Local Agency did not require sensor to be changed. Owner will replace sensor or re-program as non-discriminating.794380-341 Yes NA Pass77Yes Yes NA NA Fail YesNARepairedTechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.794380-341 Yes NA Pass64Yes Yes NA NA Fail YesNAUnkDetected product as water. Since pump shuts down for product or water, Local Agency did not require sensor to be changed. Owner will replace sensor or reprogram as non-discriminating.794380-341 Yes NA Pass77Yes Yes NA NA Fail YesNARepairedTechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.794380-341 Yes NA Pass77Yes Yes NA NA Fail YesNARepairedTechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.794380-350 Yes NA Pass84Yes NA Pass Yes Fail YesNAReplacedSensor did not come out of alarm after being tested in product, so technician replaced it.Page 4 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,Make At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSD794380-350 Yes NA Pass84Unk NA Fail No Fail NoNARe-InstalledTechnician suspected a problem with the wiring at this site.794380-350 Yes NA Pass84Unk NA Fail No Fail NoNARe-InstalledSensor alarmed, but failed PSD. Problem with the relay is suspected.794380-350 Yes NA Pass84No NA Fail No Fail NoNAReplacedSensor did not respond during high water or product testing. Technician suspected wiring problem, since sensor was replaced but test results did not change.794380-352 No NT Fail22Yes No Pass Yes NT NTNTRe-InstalledSensor's low float did not activate (would not reset). Sensor wasreplaced by the owner without informing the local agnecy northe contractor who does the routine inspection. Apparently, they did not retest sensor'sfunctinality.794380-352 Unk NT Unk200Unk Unk Pass Unk Fail UnkNTUnk794380-352 Unk NT Unk200Unk Unk Pass Unk Fail UnkNT794380-352 Yes NT NT82No NT NT NT NT NTNTUnkWiring malfunctioning.794380-352 Yes NT NT82No NT NT NT NT NTNTUnkWiring malfunctioning.794390-205 No NT NT65Yes NT NA NA Pass NANTRe-InstalledSump had oil in it. Sensor was raised above the oil, but alarmed when technician lowered it into the oil. Contractor was notified to pump out the oil that day.794390-205 No Pass NT46Yes NT NA NA NT NTYesRe-InstalledSensor was raised approximately 1 foot from bottom of the sump.794390-407 No NT NT29No NT NA NA NT NTNTRepairedThe sensor was located at the top of the tank, at the access port. The pull-string was broken. Inspector said sensor must befixed immediately. The sensor was not functionally tested during this inspection. Afollow upwas done & sensor was repaired.794390-407 Yes Fail NT73Yes NT NA NA NT NTNPRepairedSensor would not go into alarm until the techician shook it vigorously. Float was stuck. Interstice was moist, but not enoughliquid to activate an alarm.794390-407 Yes Fail NT73Yes NT NA NA NT NTNPRepairedSensor would not go into alarm until the techician shook it vigorously. Float was stuck.794390-409 Unk Fail NT81Unk NT NA NA NT NTNPRe-InstalledSensor was wedged between the primary and secondary tank walls and cannot be removed to verify sensor type. Alarm was not set at the control panel by pullingit like the prevous two tanks.794390-409 Unk Fail NT81Yes NT NA NA NT NTNPRe-InstalledSensor was wedged between the primary and secondary tank walls and cannot be removed to verify sensor type. Alarm was set at the control panel by pulling it. The response time was estimated because there was no wayof knowing when sensor was triggered.794390-420 NA Fail NT51Yes NT NA NA NT NTNPUnkThe sensor was missing the float. Follow up was made with localagency and confirmed that the technician repaired the sensor. However, inspector did not peform re-inspection.794390-420 No Pass NT55Yes NT NA NA NT NTNPUnkThis sensor is for steel tanks, and could not be wrapped around the FG tank. Local agency instructed owner to replace.Page 5 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,Make At LowPointFlip TestResultLow Test ResultSite ID / ModelLow PSD High TestResultHighPSDProductResultProductPSDAfter testingsensor wasWiredProperlyDiscriminating Flip PSD794390-420 No Pass NT89Yes NT NA NA NT NTYesRe-InstalledInterstitial space is full of water. Technician could not put back the sensor without calling the maintenance to remove water.Sensor was not at lowest point and wire was wrapped up.794390-420 No Pass NT99No NT NA NA NT NTNPWaste oil contained oil/water around the tank sump.The sensor was not located in the lowest point.794390-420 No Pass NT89Yes NT NA NA NT NTYesRe-Installed794390-420 Yes Fail NT23Yes NT NA NA NT NTNPReplacedOriginal sensor was stuck in the interstice because of rust on casing; sensor was replaced. New sensor passed test.Warrick ControlsDLP-1-NC Yes Fail NT7Yes NT NA NA NT NTNPRe-TestedSensor was sitting in water and not alarmed. Contractor shooksensor and float moved activating the alarm. Sensor passed retest after 1-2 second alarm response.Page 6 of 6All times are recorded in seconds, heights are recorded in inches. Appendix VI, Table 1,APPENDIX VI, TABLE 2Field Data for Non-discriminating SensorsTABLE 2 - Field Data for Non-Discriminating SensorSensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingSensor Make: BeaudreauSensor Model:404Operating Principle:Float SwitchUDC Veeder-Root TLS-300 Yes Yes Clean/Dry 3 1 Product NA Pass NT NT NT NTNTSensor Model:406Operating Principle:OpticalUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 2 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 2 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 2 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off No Yes Debris NT NT NT NT NT NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry None NA None NA Fail NA NA NA NANALed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry None NA None NA Fail NA NA NA NANALed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry None NA None NA Fail NA NA NA NANALed indicator light was working on sensor, indicating that the wiring was properly connected. Sensor was reinstalled, meaninglocal agency has to follow up.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 2 Both NA Pass NA NA NA NANASensor shuts off power to dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAThe sensor was tested in a cup for total darkness and shut off the valve at the dispenser.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 2 5 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Debris NT NT NT NT NT NA NA NA NANADebris and dust accumulated over the years.Page 1 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 15 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both Yes Pass NA NA NA NANASensor failed testing 6 weeks earlier. Technician replaced control module (located under dispenser) and now sensor worked.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both Yes Pass NA NA NA NANASensor failed testing 6 weeks earlier. Technician replaced control module (located under dispenser) and now sensor worked.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both Yes Pass NA NA NA NANASensor failed testing 6 weeks earlier. Technician replaced control module (located under dispenser) and now sensor worked.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both Yes Pass NA NA NA NANASensor failed testing 6 weeks earlier. Technician replaced control module (located under dispenser) and now sensor worked.UDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANAUDC Beaudreau 404-4 Cut-off Yes Yes Clean/Dry 1 1 Both NA Pass NA NA NA NANASensor Make: EmcoSensor Model:Q0003-006Operating Principle:OpticalTank Interstice Emco EECO 3000 Yes Yes Clean/Dry 60 60 Product NA Pass NA NA NA NANATank Interstice Emco EECO 3000 Yes Yes Clean/Dry 60 60 Product NA Pass NA NA NA NANATank Interstice Emco EECO 3000 Yes Yes Clean/Dry 60 60 Product NA Pass NA NA NA NANATank Interstice Emco EECO 3000 Yes Yes Clean/Dry 60 60 Product NA Pass NA NA NA NANASensor Model:Q0003-010Operating Principle:OpticalPump Sump Emco Wheaton Leak Sensor II Yes Yes Clean/Dry NT NT NT NT NT NA NA NP NANA~8 oz water in cup; panel did not support ATG, only good for open/close sensor response; pressure operating principle?Tank Interstice Emco Wheaton Leak Sensor II Yes Yes Clean/Dry NT NT NT NT NT NA NA NA NANA~8 oz water in cup; panel did not support ATG, only good for open/close sensor response; pressure operating principle?Sensor Make: GilbarcoSensor Model:PA02591144000Operating Principle:Float SwitchPage 2 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor is Gilbarco equivalent of VR model -208.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor is Gilbarco equivalent of VR model -208.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor is Gilbarco equivalent of VR model -208.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 360 1 NP PassBothUnable to remove and observe waste oil UST overfill sesor. Technician was able to to activate sensor within the tank.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 720 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 720 1 NP PassBothMid-grade and Premium share the same annular space; some condensation; sensor casing split.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT None NA NP FailNoneSensors was replaced by contractor two days after the inspection.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductThis was a two-compartment tank (midgrade and premium). The casing of the sensor was split and took the form of a bell.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry 8 5 Product NA Pass NT NT NT NTNTTank Interstice Gilbarco EMC Yes Yes Clean/Dry 9 5 Product NA Pass NT NT NT NTNTSoil in the access area for this sensor was stained dark withdiesel fuel from unknown source. Possibly overfill or surface water ingress.Tank Interstice Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT Unk Unk NP PassProductAlarm was set during the removal of the sensor from the tank interstice. Sensor was also covered with dirty water.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductPage 3 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSensor is Gilbarco equivalent of VR model -420.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSensor is Gilbarco equivalent of VR model -420.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSensor is Gilbarco equivalent of VR model -420.Sensor Model:PA02592000000Operating Principle:Float SwitchPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 840 5 NP PassBothLLD failed the 3 gph leak test. Needs replacement.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 No FailProductSensors was replaced by contractor two days after the inspection and positive shut down was rewired.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 No FailProductSensors was replaced by contractor two days after the inspection and positive shut down was rewired.Pump Sump Gilbarco EMC Yes Yes Product NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 10 1 Yes PassBothPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 840 5 NP PassBothPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 840 5 NP PassBothPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor Model:PA02592000010Operating Principle:Float SwitchPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Product NT NT NT NT NT 10 1 Yes PassBothPump Sump Gilbarco EMC Yes Yes Product NT NT NT NT NT 10 1 Yes PassBothPump Sump Gilbarco EMC Yes Yes Product NT NT NT NT NT 30 1 No FailBothRelay was stuck, so the PSD failed when tested. It passed when re-tested.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPage 4 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC No Yes Water 5 5 Product Yes Pass NT NT NT NTNT3-4 inches of water on both sides of sump (low spots of tank top).Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 7 10 Yes PassProductFlip test used since cable was too short to remove from sump for water test.Pump Sump Gilbarco EMC No Yes Water 8 8 Product Yes Pass NT NT NT NTNT2-3 inches of water on both sides of sump (low spots of tank top).Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor Model:PA0259300000-2Operating Principle:Float SwitchTank Interstice Gilbarco EMC NA Yes Brine-Filled 5 5 Product Yes Pass NT NT NT NTNTPump shut down on high and low level alarms.Tank Interstice Gilbarco EMC NA Yes Brine-Filled 5 5 Product Yes Pass NT NT NT NTNTPump shut down on high and low level alarms.Sensor Make: InconSensor Model:TS-ILSOperating Principle:OpticalTank Interstice Incon 1000ER Yes Yes Clean/Dry NT NT NT NT NT NA NA NA NANASensor Model:TSP-HISOperating Principle:Float SwitchTank Interstice Incon TS-1000 Yes Yes Brine-Filled NT NT NT NT NT 15 Unk NP PassProductThe sensor is Incon (double floats) continuously monitors the interstitial space.It was tested for both high level and low level alarms.Tank Interstice Incon TS-1000 Yes Yes Brine-Filled NT NT NT NT NT 10 Unk NP PassProductSensor Model:TSP-ULSOperating Principle:Float SwitchFill Sump Incon TS-1000 No Yes Product NT NT NT NT NT 1 15 Yes PassProductThe sump was full of diesel approximately 9 1/2 inches deep.The sensor was set at the top of the sump to avoid alarming.Fill Sump Incon TS-1000EFI Yes Yes Clean/Dry NT NT NT NT NT 5 Unk Yes PassBothPump Sump Incon Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassBothSmall metal casing with holes at bottom of sensor for liquid to enter; console had printer and ATG capability.Page 5 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Incon Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassBothSmall metal casing with holes at bottom of sensor for liquid to enter; console had printer and ATG capability.Pump Sump Incon 1000ER Yes Yes Clean/Dry NT NT NT NT NT NT NT NT NTNTPump Sump Incon TS-1000 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductThis facility does not have a positive shut-down feature.Pump Sump Incon TS-1000 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductPump Sump Incon TS-1000EFI Yes Yes Clean/Dry NT NT NT NT NT 25 Unk Yes PassBothPump Sump Incon TS-1000 Yes Yes Water NT NT NT NT NT 1 15 Yes PassProductTank Interstice Incon 1000ER Yes Yes Clean/Dry NT NT NT NT NT NT NT NT NTNTTank Interstice Incon TS-1000 NA Yes Clean/Dry NT NT NT NT NT 1 15 Yes PassProductTank Interstice Incon Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassBothSmall metal casing with holes at bottom of sensor for liquid to enter; console had printer and ATG capability.Tank Interstice Incon Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassBothSmall metal casing with holes at bottom of sensor for liquid to enter; console had printer and ATG capability.UDC Incon TS-1000 Yes Yes Product NT NT NT NT NT 1 15 Yes PassProductThere was a substantial amount of product in the UDC. There seemedto be a leak in the piping under the dispenser. It was inalarm on arrival.UDC Incon 1000ER No No Water NT NT NT NT NT NT NT NT NTNTSensor was turned off when technician conducted the test. Sensor appears to have been turned due to water in the UDC. After turning the sensor on, it passed.Sensor Make: MSASensor Model:Tankgard 482607Operating Principle:Thermal ConductivityPump Sump MSA Tankguard Yes Yes Water NT NT NT NT NT NA NA NA NANAPump Sump MSA Tankguard No No Water NT NT NT NT NT NA NA NA NANASensor initially turned off.Appears to have been turned off due to product in the sump. Sensor worked when turned on; sensornot at lowest point - about 8" above.Pump Sump MSA Tankguard Yes Yes Clean/Dry NT NT NT NT NT NA NA NA NANAHad to leave site before witnessing removal or re-installation of sensor.Tank Interstice MSA Tankguard Unk Unk Water NT NT NT NT NT NA NA NA NANASensor also is monitoring the presense of antifreeze, which shared the tank with the waste oil.Tank Interstice MSA Tankguard Yes Yes Clean/Dry NT NT NT NT NT NA NA NA NANASensor Make: Owens-Corning TankPage 6 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingSensor Model:FHRB 810Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled NT NT NT NT NT 20 Unk NP PassBothThis single sensor monitors the regular-mid-premium tanks; tworeservoirs are used (left and right) and both must be activatedfor the alarm to go off.Sensor Make: PermAlertSensor Model:PSTVOperating Principle:Float SwitchTank Interstice Red Jacket PPM 4000 Yes Yes Clean/Dry NT NT NT NT NT 3 Unk Yes PassBothSensor Make: PneumeractorSensor Model:LS 600LDOperating Principle:Float SwitchPump Sump Pneumeractor LC-1000 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductUnknown sensor type, photo taken. Flip test was done because sensor wiring prevented removal of the sensor ( wiring too short).Pump Sump Pneumeractor LC-1000 Unk Yes Water NT NT NT NT NT 2 Unk NP PassProductWater in sumps was below level of the sensor. Flip test was donedue to wiring being too short. No labels or markings on the sensor. Picture was taken.Pump Sump Pneumeractor LC-1000 Unk Yes Water NT NT NT NT NT 2 Unk NP PassProductSensor Make: Red JacketSensor Model:Liquid Refraction SensorOperating Principle:OpticalFill Sump Red Jacket PPM 4000 No Yes Water/Debris NT NT NT NT NT 2 Unk Yes PassBothSensor has been pulled up due to high water in the fill/vapor sump.Sensor Model:RE400-111-5Operating Principle:Float SwitchPump Sump Red Jacket STL 1801 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Red Jacket STL 1401 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Red Jacket STL 1401 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Red Jacket STL 1801 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Red Jacket STL 1401 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Red Jacket STL 1801 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothSensor Model:UnkOperating Principle:Float SwitchPump Sump Veeder-Root TLS-300 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPage 7 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingSensor Make: RonanSensor Model:LS-3Operating Principle:Float SwitchFill Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP FailBothFloat was stuck. Technician had to shake itto loosen it, then sensor went into alarm.Fill Sump Ronan X761VCS-3LXi Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductFill Sump Ronan X761VCS-3LXi Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductFill Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductFill Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductFill Sump Ronan X76S Yes Yes Water NT NT NT NT NT 1 1 Yes PassProductSlight amount of waterin fill sump. Not enough to activate an alarm.Fill Sump Ronan X761VCS-3LXi Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductFill Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothFill Sump Red Jacket PPM 4000 No Yes Water/Debris NT NT NT NT NT Unk Unk No FailNoneSensor appears to be good during a continuity test, but appears not to be hooked up to the control panel.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Monitoring WellEBW AutoStik Jr. 4 Yes Yes Backfill NT NT NT NT NT 1 1 NP PassProductSensor is a custom version of the LS3-A. It is made of stainless steel and is resistant to the chemicals stored in the system.Page 8 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 2 2 NP PassBothPump Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductFail-safe was verified operational.Pump Sump Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 2 1 Yes PassProductPump Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductFail-safe was verified operational.Pump Sump Ronan X76S Yes No Clean/Dry NT NT NT NT NT 3 NA Yes FailProductSensor would not come out of alarm after testing. Pump would notcome on. Contractor repaired the facility. Problem was wiring inside the building, near the control panel.Pump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 1 1 Yes PassBothPump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 1 1 Yes PassBothPump Sump Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductFail-safe was verified operational.Pump Sump Red Jacket PPM 4000 Yes No Water NT NT NT NT NT none NA No FailNoneSensor appeared to be functional when technician tested for continuity, but did not activate an alarm at the panel. Tech suspects problem with wiring between sensor and panel.Pump Sump Ronan Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassUnkThis site has a suction system and a tank sump.Pump Sump Ronan X761VCS-3LXi Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPump Sump Red Jacket PPM 4000 Yes Yes Clean/Dry NT NT NT NT NT 3 Unk Yes PassBothAfter follow up with local agency, inspector confirmed that thetechnician replaced fill sump sensor and replaced the broken wire in the monitor.Pump Sump Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductPump Sump Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductPump Sump Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 2 1 Yes PassProductPump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 1 2 NP PassBothPump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 2 2 NP PassBothPump Sump Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 2 1 Yes PassProductSensor was on its side and slightly upside-down, but not in alarm. Sensor did alarm when fully flipped over. Tech re-installedsensor properly after testing.Pump Sump Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductPump Sump Ronan X761VCS-3LXi Yes Yes Water NT NT NT NT NT 2 2 Yes PassProductPump Sump Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductPage 9 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Ronan X76S Yes Yes Water NT NT NT NT NT 2 2 NP PassBothPump Sump Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductPump Sump Ronan X761VCS-3LXi Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPump Sump Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Red Jacket PPM 4000 Yes Yes Clean/Dry NT NT NT NT NT 3 Unk Yes PassBothTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 11 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothUDC Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothSensor Model:LS-30Operating Principle:Float SwitchTank Interstice Ronan X76S NA Yes Brine-Filled NT NT NT NT NT 2 2 NP PassBothTank Interstice Ronan X76S NA Yes Brine-Filled NT NT NT NT NT 2 2 NP PassBothTank Interstice Ronan Unk NA Yes Unk 3 3 Water NA Pass NT NT NT NTNTRonan- LS-30 hydrostatic in generator tank.Tank Interstice Ronan X76S NA Yes Brine-Filled NT NT NT NT NT 2 2 NP PassBothTank Interstice Ronan X76S NA Yes Brine-Filled NT NT NT NT NT 2 2 NP PassBothPage 10 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingSensor Model:LS-7Operating Principle:Float SwitchTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTechnician pulled wire and pull string at the same time. Thislifts the sensor off the bottomof the tank interstice and allows the float to fall, activating the alarm.Tank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTechnician pulled wire and pull string at the same time. Thislifts the sensor off the bottomof the tank interstice and allows the float to fall, activating the alarm.Tank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTechnician pulled wire and pull string at the same time. Thislifts the sensor off the bottomof the tank interstice and allows the float to fall, activating the alarm.Tank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 3 1 NP PassProductTank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 3 1 NP PassProductTank Interstice Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 4 4 NP PassProductTank Interstice Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductAlarm was activated by shaking sensor while still in tank interstice.Tank Interstice Ronan X76LVC No Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductThe sensor could not be taken out of the tank interstice;therefore the sensor was activated within the tank.Tank Interstice Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductSensor had to be re-installed with a fish-tape because thestring was broken. This took the contractor about 1 hour.Tank Interstice Ronan X76S Yes Yes Clean/Dry NT NT NT NT NT 3 1 NP PassProductTank Interstice Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductAlarm was activated by shaking sensor while still in tank interstice.Tank Interstice Ronan X76LVC Yes Yes Clean/Dry NT NT NT NT NT 3 3 NP PassProductTank Interstice Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Ronan X76-4X Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Ronan X76LVC NA Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Ronan X76VS Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductAlarm was activated by shaking sensor while still in tank interstice.Sensor Model:UnkOperating Principle:Float SwitchTank Interstice Veeder-Root TLS-300 NA Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPage 11 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingSensor Make: UniversalSensor Model:LALS-1Operating Principle:Thermal ConductivityFill Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 1 Unk Both Yes Pass NA NA NA NANASensor activates an audible alarm and shuts down pump at the dispenser.Fill Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 1 Unk Both Yes Pass NA NA NA NANASensor activates an audible alarm and shuts down pump at the dispenser.Piping Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 1 Unk Both Yes Pass NA NA NA NANASensor activates an audible alarm and shuts down pump at the dispenser.Pump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NA NANAPump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 3 2 Water Yes Pass NA NA NA NANAPump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 2 Water Yes Pass NA NA NA NANAPump Sump UniversalLeak Alert LA-08 Yes Yes Vapor Odor NT NT NT NT NT 1 1 NP PassProductContractor blows on the sensor to activate the alarm. Sensor responds instantly. Sumps had been recently refinished and hadstrong chemical smell, not fuel.Pump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NP NANAPump Sump UniversalLeak Alert LA-08 Yes Yes Vapor Odor NT NT NT NT NT 1 1 NP PassProductContractor blows on the sensor to activate the alarm. Sensor responds instantly. Sumps had been recently refinished and hadstrong chemical smell, not fuel.Pump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 8 10 Water Yes Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 15 15 Water NA Pass NA NA NA NANAEmergency generator with 1000 gallon tank.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 5 3 Water Yes Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 4 4 Water Yes Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NA PassWaterContractor blows on the sensor to activate the alarm.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NA PassProductContractor blows on the sensor to activate the alarm. Sensor responds instantly.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NA PassProductContractor blows on the sensor to activate the alarm. Sensor responds instantly.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NA PassProductContractor blows on the sensor to activate the alarm. Sensor responds instantly.Page 12 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NA PassBothContractor blows on the sensor to activate the alarm.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NA PassWaterContractor blows on the sensor to activate the alarm.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 3 3 None Yes Pass NA NA NA NANATank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NA PassWaterContractor blows on the sensor to activate the alarm.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 1 Unk Both Yes Pass NA NA NA NANASensor activates an audible alarm and shuts down pump at the dispenser.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 1 Unk Both Yes Pass NA NA NA NANASensor activates an audible alarm and shuts down pump at the dispenser.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry NT NT NT NT NT None None NA FailNoneContractor waited for 2 minutes for the sensor to response, but never did. Sensor had to be replaced.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry None NA None No Fail NA NA NA NANASensor was not tested because it was stuck in the interstitial space.Tank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 Unk Product NA Pass NA NA NA NANASensor Model:LAVS-1Operating Principle:Metal Oxide SemiconductorTank Interstice UniversalLeak Alert LA-08 Yes Yes Clean/Dry Unk Unk Unk No Fail NA NA NA NANASensor Model:LS 03875 STP SensorOperating Principle:Thermal ConductivityPump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 33 Product Yes Pass NA NA NP NANAThere was no light bulb on the monitoring panel, but alarm activated.Pump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 11 Product Yes Pass NA NA NA NANAThere was no light bulb on the monitoring panel, but alarm activated.Pump Sump UniversalLeak Alert LA-08 Yes Yes Clean/Dry 2 15 Product Yes Pass NA NA NP NANAThere was no light bulb on the monitoring panel, but alarm activated.Sensor Make: Veeder-RootSensor Model:330212-001Operating Principle:Float SwitchUDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPage 13 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingUDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 1 MR NP PassBothSensor cuts power to dispenser, which must be manually reset.UDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 2 1 Yes PassProductUDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductUDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductUDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 1 MR NP PassBothSensor cuts power to dispenser, which must be manually reset.UDC Veeder-Root Dispenser cut-off Yes Yes Clean/Dry NT NT NT NT NT 10 MR NP PassBothSensor cuts power to dispenser, which must be manually reset.Sensor Model:331102-002Operating Principle:Float SwitchPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 1 Yes PassBothSensor has double float alarm (high/low). Service technician decided only to do the flip test.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassBothSensor has double float alarm (high/low). Service technician decided only to do the flip test.Sensor Model:794380-208Operating Principle:Float SwitchATG Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT Unk Unk NP PassProductSump contains dirty water. Alarm was set at the control panel.ATG Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT Unk Unk NP PassProductSump contains dirty water. Alarm was set at the control panel.ATG Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT Unk Unk NP PassProductSump contains dirty water. Alarm was set at the control panelATG Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductATG Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductATG Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductFill Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 3 3 Yes PassProductFill sump contains water, dirt, and corrosion.Fill Sump Veeder-Root TLS-350 Yes Yes Debris NT NT NT NT NT 3 2 NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 2 2 NP PassProductSensor was in alarm when technician arrived to conduct inspection. Technician called to have the product removed.Fill Sump Veeder-Root TLS-350 No Yes Water NT NT NT NT NT 2 2 NP PassProductPage 14 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingFill Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 2 2 NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductFill Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 10 2 Yes PassProductFill Sump Veeder-Root TLS-350 Yes Yes Debris NT NT NT NT NT 2 2 NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 Unk Product NA Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 8 Unk NP PassProductFill sump contains waste oil.Fill Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 8 Unk NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 8 Unk NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 8 Unk NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 10 5 Product Yes Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 8 5 Product Yes Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothFill Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothFill Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT none NA No FailNoneTechnician waited for over 2 minutes, but sensor did not alarm.Finally inspector decided to call the test off and replace thesensor. Testing was done on the new sensor and it passed.Fill Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductFill Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 5 1 Yes PassProductFill Sump Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 5 6 NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 12 2 Yes PassProductFill Sump Veeder-Root TLS-350 No Yes Water NT NT NT NT NT 15 1 Yes PassProductThe sensor was not located at the lowest point inthe tank. Technician lowered it and activetd an alarm.Fill Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 6 Yes PassProductPage 15 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingFill Sump Veeder-Root TLS-350 No Yes Water NT NT NT NT NT 5 1 NP PassProductContains a substantial amount of water.Fill Sump Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 5 6 Yes PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductThe sensor was not at the lowest point in the tank.Fill Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 5 Yes PassProductSump has 4-5 inches of water. Technician was waiting for maintinance to clean the water before putting back the sensor.Fill Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 5 Yes PassProductSump has 4-5 inches of water. Technician was waiting for maintinance to clean the water before putting back the sensor.Piping Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk NP PassProductAlarm was set at the control panel.Pump Sump Veeder-Root TLS-350 Yes Yes Water 5 2 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Water 5 2 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Water 5 2 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 seconds.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 secondsPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk NP PassProductAlarm was set at the control panel.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 6 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 5 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductThe cable is too short to test sensor in liquid, Instead perform a flip test.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductPage 16 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 secondsPump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 5 1 Yes PassProductPump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 5 1 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 10 4 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 12 4 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk NP PassProductAlarm was set at the control panel.Pump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 4 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 10 4 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductPump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothPump Sump Unk Unk Yes Yes Clean/Dry NT NT NT NT NT 6 6 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 8 4 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 7 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 10 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductCable was too short to allow for testing in liquid. Flip test was used.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductCable was too short to allow for testing in liquid. Flip test was used.Page 17 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductCable was too short to allow for testing in liquid. Flip test was used.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk Unk PassProductTested 4 of VR 208 sensors, all 4 alarms were set.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk Unk PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk Unk PassProductPump Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 6 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductPump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 3 3 NP PassProduct2-3 gallons of product in the sump. Sensor was raised above the product level. Sensor in pump sump was not programmed to shutdown pump.Pump Sump Veeder-Root Unk No Yes Water 25 17 Water Yes Pass NT NT NT NTNTFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)Pump Sump Veeder-Root Unk No Yes Water 20 20 Water Yes Pass NT NT NT NTNTFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)Pump Sump Veeder-Root Unk No Yes Water 20 20 Water Yes Pass NT NT NT NTNTFill bucket was detached. Stick was in the product line(to prevent the flapper from shutting down the flow)Pump Sump Veeder-Root Unk No Yes Water 20 15 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shut down the pump.Pump Sump Veeder-Root Unk No Yes Water 25 30 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shut down the pump.Pump Sump Veeder-Root Unk No Yes Water 20 30 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shut down the pump.Pump Sump Veeder-Root Unk No Yes Water 20 20 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shut down the pump.Pump Sump Veeder-Root Unk No Yes Water 20 15 Water Yes Pass NT NT NT NTNTFill bucket was detached. Stick was in the product line (to prevent the flapper from shutting down the flow). Most of sensors timed out & Technician had to go and re-set it to shut down the pump.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk Unk PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 3 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPage 18 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 No Yes Water NT NT NT NT NT 2 Unk Yes PassProduct2 sensors, 1 raised in sump and the other was a the lowest point. Both responded and activated pump shut off. Picture of sensor was taken.Pump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 2 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 15 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor was raised about 4 inchesfrom the bottom of the sump.Pump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 3 3 NP PassProduct2-3 gallons of product in the sump. Sensor was raised above the product level. Sensor in pump sump was not programmed to shutdown pump.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 12 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 Yes PassProductPump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 8 10 Yes PassProductProduct is leaking out of the top of the turbine pump.Pump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 8 10 Yes PassProductProduct is leaking out of the top of the turbine pump.Pump Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT 8 10 Yes PassProductProduct is leaking out of the top of the turbine pump.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 4 Yes PassProductNoticed a 1" hole in the sump, which will need to berepaired in order to have tight secondary containment.Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-300 Yes Yes Clean/Dry NT NT NT NT NT 30 Unk NP PassProductPage 19 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 4 5 Yes PassProductThere was a hole in the sump, approximately 1 1/2" diam. Electrical wiring below penetration lines. Hydrostatic test was performed to the highest penetration lines at 16 minutes per cycle.Test at 16 psi and fail ifbelow 12 psi. Fill sump is not clean..Pump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NTer 2mNA No FailNoneThe contractor decided to stop testing the sensor after it failedto respond for more than 2 minutes and replace it with a newsensor.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 4 Yes PassNAPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 3 Yes PassProductPump Sump Unk Unk Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 4 Yes PassProductPump Sump Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 5 8 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 NP PassBothPump Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 5 Yes PassProductSump has 4-5 inches of water. Technician was waiting for maintinance to clean the water before putting back the sensor.Pump Sump Veeder-Root Unk Yes Yes Water NT NT NT NT NT 5 5 Yes PassProductSump has 4-5 inches of water. Technician was waiting for maintinance to clean the water before putting back the sensor.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry 10 5 Product Yes Pass NT NT NT NTNTUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry 15 10 Product Yes Pass NT NT NT NTNTUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 15 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductPage 20 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductTested six dispensers, all passed-alarms set (total ofsix triggers), all six sensors (VR 208) are working.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 secondsUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 2 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry 15 10 Product Yes Pass NT NT NT NTNTUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry 10 5 Product Yes Pass NT NT NT NTNTUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 secondsUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductFlip Test- estimated response of 10 secondsUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NA PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 4 Yes PassProductUDC Veeder-Root Unk Yes Yes Clean/Dry 20 20 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shutdown the pump. Technician conducts water and flip test in some ofthe sensors because the wire did not reach te water bucket.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductUDC Veeder-Root Unk Yes Yes Clean/Dry 20 25 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shutdown the pump. Technician conducts water and flip test in some ofthe sensors because the wire did not reach te water bucket.UDC Veeder-Root Unk Yes Yes Clean/Dry 22 22 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shut down the pump. Technician conductswater and flip test in some ofthe sensors because the wire did not reach the water bucket.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductPage 21 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingUDC Veeder-Root Unk Yes Yes Clean/Dry 22 22 Water Yes Pass NT NT NT NTNTUDC Veeder-Root Unk Yes Yes Clean/Dry 21 21 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shutdown the pump. Technician conducts water and flip test in some ofthe sensors because the wire did not reach te water bucket.UDC Veeder-Root Unk Yes Yes Clean/Dry 25 22 Water Yes Pass NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shutdown the pump. Technician conducts water and flip test in some ofthe sensors because the wire did not reach te water bucket.UDC Veeder-Root Unk Yes Yes Clean/Dry 22 22 Water Yes Pass NT NT NT NTNTUDC Veeder-Root Unk Yes Yes Clean/Dry 20 20 Unk Unk Unk NT NT NT NTNTSensor timed out & Technician had to go and re-set it to shutdown the pump. Technician conducts water and flip test in some ofthe sensors because the wire did not reach te water bucket.Unk Veeder-Root TLS-350 No Yes Water NT NT NT NT NT 2 2 No FailProductAlarm activated at the control panel, but no pump shutdown. ( printer said pump shutdown occurred, but pump continued to run.Picture of sensor is site 7 #2.). Follow up was done on this site and Inspectorconfirmed that the PSD is functioning properly.Vault Gilbarco Unk Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductSingle wall steel tank inside aVault. Vapor recovery fill bucket is half way full of water.Sensor Model:794380-209Operating Principle:Float SwitchPump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 12 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 12 Unk Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 12 Unk Yes PassProductSensor Model:794380-300Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-300 NA Yes Brine-Filled 2 2 Water NA Pass NT NT NT NTNTSensor Model:794380-301Operating Principle:Float SwitchTank Interstice Veeder-Root Simplicity Yes Yes Brine-Filled NT NT NT NT NT 6 1 Yes PassBothTank Interstice Veeder-Root Simplicity Yes Yes Brine-Filled NT NT NT NT NT 6 1 Yes PassBothTank Interstice Veeder-Root Simplicity Yes Yes Brine-Filled NT NT NT NT NT 6 1 Yes PassBothSensor Model:794380-302Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 20 15 Water NA Pass NT NT NT NTNTTechnician lifted sensor out of brine reservoir to activate the "low water level" alarm.Tank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 10 Unk Low Brine Level Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 10 Unk Low Brine Level Yes Pass NT NT NT NTNTPage 22 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 20 15 Water NA Pass NT NT NT NTNTTechnician lifted sensor out of brine reservoir to activate the "low water level" alarm.Tank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 30 10 Water NA Pass NT NT NT NTNTTechnician lifted sensor out of brine reservoir to activate the "low water level" alarm.Tank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 10 Unk Low Brine Level Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 NA Yes Brine-Filled 30 10 Water NA Pass NT NT NT NTNTTechnician lifted sensor out of brine reservoir to activate the "low water level" alarm.Sensor Model:794380-408Operating Principle:Float SwitchUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk NP PassProductAlarm set at the control panel, sensor is not programmed for pump shut down or dispenser shut down.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk NP PassProductAlarm set at the control panel, sensor is not programmed for pump shut down or dispenser shut down.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk NP PassProductAlarm set at the control panel, sensor is not programmed for pump shut down or dispenser shut down.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 6 Unk NP PassProductAlarm set at the control panel, sensor is not programmed for pump shut down or dispenser shut down.Sensor Model:794380-500Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-300 NA Yes Brine-Filled 2 2 Water NA Pass NT NT NT NTNTSensor Model:794390-205Operating Principle:Float SwitchFill Sump Veeder-Root TLS-350 No Yes Product NT NT NT NT NT NT NT NT NTNTSump had oil in it. Sensor was raised above the oil, but alarmed when technician lowered it into the oil. Contractor was notified to pump out the oil that day.Fill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product NA Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product NA Pass NT NT NT NTNTFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductFill Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 10 10 Yes PassProductSensor was Gilbarco equivalent of Veeder Root Model 794380-205.Cable was too short to test the sensor in liquid, so flip testwas used.Fill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 6 NP PassProductFill Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 6 NP PassProductPage 23 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingFill Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor was Gilbarco equivalent of Veeder Root Model 794380-205.Cable was too short to test the sensor in liquid, so flip testwas used.Pump Sump Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 90 Unk NP PassProductsensor is not programmed for positive shut down, only sets an audible alarm.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 8 6 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 6 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 25 5 Yes PassBothSome condensation on sump.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 90 Unk NP PassProductsensor is not programmed for positive shut down, only sets an audible alarm.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry 10 5 Product Yes Pass NT NT NT NTNTPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 90 Unk NP PassProductsensor is not programmed for positive shut down, only sets an audible alarm.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 5 Yes PassBothPump Sump Veeder-Root TLS-350 Yes Yes Product NT NT NT NT NT 5 1 NP PassBoth1 inch of kerosene in sump; this sensorwas tested with just an alarm first; retesting while running pump and the pump did notshut off.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 20 5 Yes PassBothPump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 10 10 Yes PassProductSensor was Gilbarco equivalent of Veeder Root Model 794380-205.Cable was too short to test the sensor in liquid, so flip testwas used.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 20 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 5 Yes PassBothFor this tank, there are two sumps, but only one sensor (the sumps are linked).Pump Sump Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductSensor was Gilbarco equivalent of Veeder Root Model 794380-205.Cable was too short to test the sensor in liquid, so flip testwas used.Pump Sump Veeder-Root TLS-350 No Yes Clean/Dry NT NT NT NT NT 15 10 Yes PassProductSensor was raised approximately 1 foot from bottom of the sump.Pump Sump Veeder-Root TLS-350 Unk Yes Water NT NT NT NT NT 1 2 Yes PassProductPage 24 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Unk Yes Water NT NT NT NT NT 5 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 1 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 1 1 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 1 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 20 5 Yes PassBothDiesel tank interstice 50m from sump.Tank Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 25 Unk NP PassProductSuction system with tank top sump.UDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductSensor Model:794390-407Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-350 No No Clean/Dry NT NT NT NT NT NT NT NT NTNTThe sensor was located at the top of the tank, at the access port.The pull-string was broken. Inspector said sensor must befixed immediately. The sensor was not functionally tested during this inspection. Afollowup was done & sensor was repaired.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductWrap-around sensor. Techician moved sensor toward top of tank until alarm sounded. Did not completely remove the sensor.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductWrap-around sensor. Techician moved sensor toward top of tank until alarm sounded. Did not completely remove the sensor.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductWrap-around sensor. Techician moved sensor toward top of tank until alarm sounded. Did not completely remove the sensor.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 5 5 NP FailProductSensor would not go into alarm until the techician shook it vigorously. Float was stuck. Interstice was moist, but not enoughliquid to activate an alarm.Page 25 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductTechnician pulled sensor around the tank until alarm activated,but did not fully remove the sensor from the annular space.Tank Interstice Veeder-Root TLS-350 NA Yes Clean/Dry NT NT NT NT NT 2 10 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk NP PassProductAlarm was set during the removal of the sensor from the tank interstice.Tank Interstice Veeder-Root TLS-350 NA Yes Clean/Dry NT NT NT NT NT 2 15 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT Unk Unk NP PassProductAlarm was set during the removal of the sensor from the tank interstice.Tank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductTechnician pulled sensor around the tank until alarm activated,but did not fully remove the sensor from the annular space.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP FailProductSensor would not go into alarm until the techician shook it vigorously. Float was stuck.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductTechnician pulled sensor around the tank until alarm activated,but did not fully remove the sensor from the annular space.Tank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 10 NP PassProductTechnician pulled sensor around the tank until alarm activated,but did not fully remove the sensor from the annular space.Sensor Model:794390-409Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-350 NA Yes Clean/Dry NT NT NT NT NT 3 2 Yes PassProductTank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 2 2 Yes PassProductTank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 9 Unk NP PassProductSensor is not set up for pump shut down.Tank Interstice Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 17 17 Yes PassProductThree tanks ( 1 split gasoline tank & 2 diesel tanks)Tank Interstice Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 20 20 Yes PassProductPage 26 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 20 20 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk NP PassProductTested 4 of 409 sensors, all appeared to be dry and clean; alarms set for all sensors.Tank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 10 10 NP PassProductFlip Test - Approximately 10 Seconds.Tank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 10 10 NP PassProductFlip Test - Approximately 10 Seconds.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 15 Unk Unk PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 9 Unk NP PassProductSensor is not set up for pump shut down.Tank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 75 Unk NP FailProductSensor was wedged between the primary and secondary tank walls and cannot be removed to verify sensor type. Alarm was set at the control panel by pulling it. The response time was estimated because there wasno way of knowing when sensor was triggered.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 45 Unk NP PassProductFollow up was made on this site with the local agnecy and assured that next day, the contractor replaced the broken sensors. Inspector did not re-inspect, but received a report from the contractor indicating that thesensor is working properly.Tank Interstice Veeder-Root TLS-350 Unk Unk Clean/Dry NT NT NT NT NT None Unk NP FailNoneSensor was wedged between the primary and secondary tank walls and cannot be removed to verify sensor type. Alarm was not set at the control panel by pullingit like the prevous two tanks.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Unk NT NT NT NT NT 10 10 NP PassProductFlip Test - Approximately 10 Seconds.Sensor Model:794390-420Operating Principle:Float SwitchPiping Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProduct3 small steel pipes (1 for each generator) were run within one large steel pipe. The sensor monitors the large pipe, which stays dry unless the small pipes leak.Piping Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProduct3 small steel pipes (1 for each generator) were run within one large steel pipe. The sensor monitors the large pipe, which stays dry unless the small pipes leak.Piping Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProduct3 small steel pipes (1 for each generator) were run within one large steel pipe. The sensor monitors the large pipe, which stays dry unless the small pipes leak.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPage 27 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 No No Water NT NT NT NT NT 5 5 NP PassProductWaste oil contained oil/water around the tank sump.The sensor was not located in the lowest point.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 2 Yes PassProductThe sump contained product.Pump Sump Veeder-Root TLS-320 Yes Yes Clean/Dry NT NT NT NT NT 4 2 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Water/Product NT NT NT NT NT 10 5 Yes PassProductSensor was sitting in 3-4 inches of water/product but was notin alarm. However, sensor activated alarm when flipped.Pump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 NA NA Clean/Dry NT NT NT NT NT 5 3 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Veeder-Root TLS-350 Unk Yes Clean/Dry NT NT NT NT NT 1 1 NP PassProductTank Interstice Veeder-Root TLS-350 NA NA Clean/Dry NT NT NT NT NT 5 3 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductContractor mentioned that this type of sensors are constantlycracking and split out in age(chronic problem). Maybe it’s a design problem.Even when sensors are cracked, contractor usually don’t replace them.Tank Interstice Veeder-Root Unk No Yes Water NT NT NT NT NT 4 4 Yes PassProductInterstitial space is full of water. Technician could not put back the sensor without calling the maintenance to remove water.Sensor was not at lowest point and wire was wrapped up.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSensor casing was corroded and cracked. This is a chronic problemwith this model. Even whencracked, contractor does not replace them because they all tend to be like that after a while.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root Unk No Yes Water NT NT NT NT NT 4 4 Yes PassProductTank Interstice Veeder-Root TLS-350 NA NA Clean/Dry NT NT NT NT NT 5 3 NP PassProductTank Interstice Veeder-Root Unk Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 25 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProductPage 28 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Pneumeractor LC-1000 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Pneumeractor LC-1000 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Water NT NT NT NT NT 5 Unk NP PassProductSensor was wet when removed from tank interstice. It is unknown how much liquid was in interstice.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 Unk Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product NA Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product NA Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 3 3 Product NA Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 10 Unk NP PassProduct.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 Unk Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductPage 29 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root TLS-300 No Yes Clean/Dry NT NT NT NT NT 30 Unk NP PassProductThis sensor is for steel tanks, and could not be wrapped around the FG tank. Local agency instructed owner to replace.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT None NA NP FailBothOriginal sensor was stuck in the interstice because of rust on casing; sensor was replaced. New sensor passed test.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry 5 5 Product Yes Pass NT NT NT NTNTTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 Unk Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSteel sensor casing was split.Tank Interstice Gilbarco EMC Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSteel sensor casing was split.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 1 1 NP PassBothTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 3 3 NP PassProductTank Interstice Veeder-Root TLS-350 NA Yes Clean/Dry NT NT NT NT NT None NA NP FailNoneThe sensor was missing the float. Follow up was made with localagency and confirmed that the technician repaired the sensor. However, inspector did not peform re-inspection.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductPage 30 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,SensorLocationPanelMakePanelModelAt LowPointWiringOKConditionof LocationResp Rec Alarm PSD Result Resp Rec PSD ResultAlarmLiquid Testing Flip TestingTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductSensor housing (steel bell) was split.Tank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 2 2 Yes PassProductSensor Model:794390-460Operating Principle:Float SwitchTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductTank Interstice Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 5 5 NP PassProductUDC Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 4 1 Yes PassProductSensor Model:847990-001Operating Principle:Float SwitchPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 20 5 Yes PassBothPump Sump Veeder-Root TLS-350 Yes Yes Clean/Dry NT NT NT NT NT 20 5 Yes PassBothUDCDispenser Cut-offUnk Yes Yes Clean/Dry 1 MR Unk NA Pass NT NT NT NTNTThe sensor cuts power to dispensers. Dispenser had to be manually reset to clear alarm.UDCDispenser Cut-offUnk Yes Yes Clean/Dry 2 MR Unk NA Pass NT NT NT NTNTThe sensor cuts power to dispensers. Dispenser had to be manually reset to clear alarm.UDCDispenser Cut-offUnk Yes Yes Clean/Dry 3 MR Unk NA Pass NT NT NT NTNTThe sensor cuts power to dispensers. Dispenser had to be manually reset to clear alarm.UDCDispenser Cut-offUnk Yes Yes Clean/Dry 2 MR Unk NA Pass NT NT NT NTNTThe sensor cuts power to dispensers. Dispenser had to be manually reset to clear alarm.Sensor Make: Warrick ControlsSensor Model:DLP-1-NCOperating Principle:Float SwitchPump Sump Warrick Unk Yes Yes Water NT NT NT NT NT None NA NP FailNoneSensor was sitting in water and not alarmed. Contractor shooksensor and float moved activating the alarm. Sensor passed retest after 1-2 second alarm response.Pump Sump Warrick Unk Yes Yes Water NT NT NT NT NT Unk Unk NP PassBothPage 31 of 31All times are recorded in seconds and heights in inches.Appendix VI, Table 2,APPENDIX VI, TABLE 3Field Data for Discriminating SensorsTABLE 3 - Field Data for Discriminating SensorsResp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingSensor Make: Alpha wireSensor ModelUnkNT NT NT NT NT NA NA NA NA NA NT NT NT NT NT 60 60 Product NP PassNT NT NT NT NT NA NA NA NA NA NT NT NT NT NT None NA None NP FailSensor Make: EmcoSensor ModelQ0003-00160 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.Sensor ModelQ0003-00260 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 60 Water NA Pass 60 60 Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 60 Water NA Pass 60 60 Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.60 Unk Water NA Pass 60 Unk Water Yes Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not require discriminating sensors to be tested in product.Sensor Make: InconSensor ModelTSP-DIS4 Unk Both Yes Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NASensor Make: Mallory ControlsPage 1 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingSensor ModelPollulert FD 221GTRA10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.Sensor ModelPollulert MD 241RRA10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.10 Dry Water NA Pass NA NA NA NA NA 10 Dry Product NA Pass NA NA NA NA NASensor had to be wiped dry to come out of alarm.NT NT NT NT NT NA NA NA NA NA 10 10 Product Yes Pass NA NA NA NA NANT NT NT NT NT NA NA NA NA NA NA NA None No Fail NA NA NA NA NASensor failed the test, but the company is out of business.So,owner might have to change the system. Inspector gave the ownertwo weeks to fix it or replace It.NT NT NT NT NT NA NA NA NA NA 20 10 Product Yes Pass NA NA NA NA NASensor Make: Red JacketSensor ModelRE400-2031 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NA1 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NA1 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NA1 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NA1 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NA1 1 Water NA Pass NA NA NA NA NA NT NT NT NT NT NA NA NA NA NASensor Make: Veeder-RootSensor Model794380-320Unk Unk Unk Unk Unk 2 5 Water Unk Pass 383 1030 Product Unk Pass NA NA NA NA NAUnk Unk Unk Unk Unk 1 7 Water Unk Pass 395 962 Product Unk Pass NA NA NA NA NASensor Model794380-3225 Unk Water NA Pass 5 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTTechnician flipped the sensor, activating both low and high water alarms at the same time.Page 2 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingSensor Model794380-341NT NT NT NT NT 5 1 Water Yes Pass 5 1 Product Yes Pass NA NA NA NA NAWhen placed in fuel, alarms went off as water - pump shut-down worked; waste oil sensor failed, replaced and recorded on separate sheet.10 10 Water Yes Pass NA NA NA NA NA 10 10 Water Yes Fail NA NA NA NA NATechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.10 10 Water Yes Pass NA NA NA NA NA 10 10 Water Yes Fail NA NA NA NA NATechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.10 10 Water Yes Pass NA NA NA NA NA 10 10 Water Yes Fail NA NA NA NA NATechnician had to clean the sensor with arag completely (especially in the small windowat sensor's center) before fuel couldbe detected. After cleaning sensor did detect fuel.Unk Unk Unk Unk Unk NA NA NA NA NA NA NA None Unk Fail NA NA NA NA NAUnk Unk Unk Unk Unk NA NA NA NA NA 2 2 Product Unk Pass NA NA NA NA NAUnk Unk Unk Unk Unk NA NA NA NA NA 2570 4240 Product Unk Pass NA NA NA NA NAUnk Unk Unk Unk Unk NA NA NA NA NA 5 5 Product Unk Pass NA NA NA NA NA3 3 Water Yes Pass NA NA NA NA NA 3 3 Product Yes Pass NA NA NA NA NA12 1 Water NA Pass NA 0 NA NA NA 13 Unk Water No Fail NA NA NA NA NASensor sets water alarm for product test. After testing the sensor was replaced and the new sensor was setting the right alarm.NT NT NT NT NT 5 1 Water Yes Pass 5 1 Product Yes Pass NA NA NA NA NANT NT NT NT NT 5 1 Water Yes Pass 5 1 Product Yes Pass NA NA NA NA NANT NT NT NT NT NA NA NA NA NA Unk Unk None No Fail NA NA NA NA NAReplaced with same type of sensor.3 2 Both Yes Pass NA NA NA NA NA 3 2 Both Yes Pass NA NA NA NA NASensor had been programmed to give the same alarm in water and product.3 2 Both Yes Pass NA NA NA NA NA 3 2 Both Yes Pass NA NA NA NA NASensor had been programmed to give the same alarm in water and product.3 2 Both Yes Pass NA NA NA NA NA 3 2 Both Yes Pass NA NA NA NA NASensor had been programmed to give the same alarm in water and product.3 3 Water Yes Pass NA NA NA NA NA 3 3 Water Yes Fail NA NA NA NA NADetected product as water. Since pump shuts down for product or water, Local Agency did not require sensor to be changed. Owner will replace sensor or re-program as non-discriminating.12 1 Water NA Pass NA 0 NA NA NA 13 Unk Product Yes Pass NA NA NA NA NAUnk Unk Unk Unk Unk NA NA NA NA NA 2 2 Product Unk Pass NA NA NA NA NA12 1 Water NA Pass NA 0 NA NA NA 12 Unk Water No Fail NA NA NA NA NASensor sets water alarm for product test. After testing, sensor was replaced and the new sensor was setting the right alarm.NT NT NT NT NT NA 0 NA NA NA 13 Unk Water NA Fail NA NA NA NA NASensor was tested with both unleaded gasoline and waste oil. Bothcases, water alarms were observed. Sensor was not approved for use in waste oil. After testing, sensor was replaced and it passed the product test.Unk Unk Unk Unk Unk NA NA NA NA NA NA NA None Unk Fail NA NA NA NA NAUnk Unk Unk Unk Unk 3 10 Water Unk Pass 358 2450 Product Unk Pass NA NA NA NA NAPage 3 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingUnk Unk Unk Unk Unk NA NA NA NA NA 4 10 Product Unk Pass NA NA NA NA NAUnk Unk Unk Unk Unk NA NA NA NA NA 417 1055 Product Unk Pass NA NA NA NA NA3 3 Water Yes Pass NA NA NA NA NA 3 3 Water Yes Fail NA NA NA NA NADetected product as water. Since pump shuts down for product or water, Local Agency did not require sensor to be changed. Owner will replace sensor or reprogram as non-discriminating.Sensor Model794380-3505 5 Water NA Pass 5 5 Water Yes Pass 360 465 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.1 1 Water NA Pass 5 5 Water Yes Pass 360 765 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.2 2 Water NA Pass 2 2 Water Yes Pass 300 480 Product Yes Pass NA NA NA NA NA2 2 Water NA Pass 2 Unk Water Yes Pass 480 Non Product Yes Fail NA NA NA NA NASensor did not come out of alarm after being tested in product, so technician replaced it.2 2 Water NA Pass None Non None No Fail none Unk None No Fail NA NA NA NA NASensor did not respond during high water or product testing. Technician suspected wiring problem, since sensor was replaced but test results did not change.2 2 Water NA Pass 2 2 Water Yes Pass 180 NA Product Yes Pass NA NA NA NA NA2 2 Water NA Pass 2 2 Water No Fail Unk Unk Product No Fail NA NA NA NA NATechnician suspected a problem with the wiring at this site.5 5 Water NA Pass 5 5 Water NA Pass 480 300 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.1 1 Water NA Pass 5 5 Water Yes Pass 330 600 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 Unk Water NA Pass 2 2 Water Yes Pass 300 600 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.5 5 Water NA Pass 5 5 Water Yes Pass 300 360 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 5 Water NA Pass 5 5 Water Yes Pass 330 420 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 5 Water NA Pass 5 5 Water NA Pass 300 540 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 5 Water NA Pass 5 5 Water NA Pass 720 360 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 5 Water NA Pass 5 5 Water NA Pass 360 1500 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.5 Unk Water NA Pass 2 2 Water Yes Pass 420 720 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.1 1 Water NA Pass 5 5 Water Yes Pass 300 540 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.Page 4 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip Testing7 1 Water NA Pass 3 1 Water Yes Pass 360 720 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.NT NT NT NT NT 5 1 Water Yes Pass 360 900 Product Yes Pass NA NA NA NA NANT NT NT NT NT 5 1 Water Yes Pass 360 900 Product Yes Pass NA NA NA NA NANT NT NT NT NT 5 1 Water Yes Pass 360 900 Product Yes Pass NA NA NA NA NANT NT NT NT NT 5 1 Water Yes Pass 840 Unk Product Yes Pass NA NA NA NA NATakes longer for this sensor to alarm because often left sitting in water.7 1 Water NA Pass 5 1 Water Yes Pass 300 300 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.7 1 Water NA Pass 4 1 Water Yes Pass 360 590 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.7 1 Water NA Pass 5 1 Water Yes Pass 360 660 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.Unk Unk Unk Unk Unk 4 5 Water Unk Pass 238 3531 Product Unk Pass NA NA NA NA NA7 1 Water NA Pass 6 1 Water Yes Pass 360 1020 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.5 Unk Water NA Pass 2 2 Water Yes Pass 300 600 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.Unk Unk Unk Unk Unk 2 10 Water Unk Pass 365 1100 Product Unk Pass NA NA NA NA NAUnk Unk Unk Unk Unk 4 7 Water Unk Pass 357 890 Product Unk Pass NA NA NA NA NA2 2 Water NA Pass 2 2 Water No Fail Unk Unk Product No Fail NA NA NA NA NASensor alarmed, but failed PSD. Problem with the relay is suspected.Unk Unk Unk Unk Unk 3 9 Water Unk Pass 206 1390 Product Unk Pass NA NA NA NA NA5 Unk Water NA Pass 2 2 Water Yes Pass 300 600 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.5 5 Water NA Pass 5 5 Water NA Pass 420 420 Product Yes Pass NA NA NA NA NATechnician left sensor in product for 2min & 45sec. He rinsedthe sensor with soapy water after alarm activated to speed up recovery time.Unk Unk Unk Unk Unk 5 10 Water Unk Pass 318 1189 Product Unk Pass NA NA NA NA NA5 Unk Water NA Pass 2 2 Water Yes Pass 420 720 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.7 1 Water NA Pass 6 1 Water Yes Pass 300 483 Product Yes Pass NA NA NA NA NAFor product test, sensor was left in fuel for 3 minutes.Unk Unk Unk Unk Unk 4 9 Water Unk Pass 3009 6120 Product Unk Pass NA NA NA NA NA5 Unk Water NA Pass 2 2 Water Yes Pass 300 600 Product Yes Pass NA NA NA NA NASensors were left in fuel for 3 minutes. They alarm 2-5 minutes after being pulled from fuel. This speeds up recovery time.Sensor Model794380-3523 1 Both Yes Pass 3 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NTPage 5 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip Testing6 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTSensors were tested as a non-discriminating float sensor.6 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTSensors were tested as a non-discriminating float sensor.NT NT NT NT NT 5 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NTThese sensors were located in the fill sump, in the overfill bucket.NT NT NT NT NT 1 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NTThese sensors were located in the fill sump, in the overfill bucket.NT NT NT NT NT 5 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NTThese sensors were located in the fill sump, in the overfill bucket.3 1 Both Yes Pass 3 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NT10 5 Water NA Pass 10 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTFlip test activated both low and high liquid alarms. Technician did not test the sensor in product.10 5 Water NA Pass 10 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTFlip test activated both low and high liquid alarms. Technician did not test the sensor in product.10 5 Water NA Pass 10 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTFlip test activated both low and high liquid alarms. Technician did not test the sensor in product.15 5 Water NA Pass 15 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTFlip test activated both low and high liquid alarms. Techniciandid not test the sensor in product. Water in sump was not high enough to activate the alarm.5 Unk Water NA Pass 5 Unk Water Unk Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not test discriminating sensors in product. Both low and high level alarms wereactivated by flipping the sensor.5 Unk Water NA Pass 5 Unk Water Unk Pass NT NT NT NT NT NT NT NT NT NTLocal agency did not test discriminating sensors in product. Both low and high level alarms wereactivated by flipping the sensor.Unk Unk None No Fail 3 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NTSensor's low float did not activate (would not reset). Sensor wasreplaced by the owner without informing the local agnecy northe contractor who does the routine inspection. Apparently, they did not retest sensor'sfunctinality.Unk Unk Unk Unk Unk 10 17 Water Unk Pass 425 2435 Product Unk Pass NT NT NT NT NTCleaned in Coleman Fuel.Unk Unk Unk Unk Unk 8 16 Water Unk Pass 446 1548 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 12 18 Water Unk Pass 468 960 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 10 Water Unk Pass 452 960 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 11 Water Unk Pass NA NA Water Unk Fail NT NT NT NT NTUnk Unk Unk Unk Unk NT NT NT NT NT 543 570 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 10 18 Water Unk Pass 275 2595 Product Unk Pass NT NT NT NT NTCleaned in Coleman Fuel.6 1 Both Yes Pass NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTSensors were tested as a non-discriminating float sensor.Unk Unk Unk Unk Unk 7 13 Water Unk Pass 425 1413 Product Unk Pass NT NT NT NT NTPage 6 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingUnk Unk Unk Unk Unk 6 16 Water Unk Pass 435 2040 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 9 22 Water Unk Pass 530 2040 Product Unk Pass NT NT NT NT NTCleaned in Coleman Fuel.Unk Unk Unk Unk Unk 4 14 Water Unk Pass 355 1640 Product Unk Pass NT NT NT NT NTCleaned in Coleman Fuel.Unk Unk Unk Unk Unk 5 13 Water Unk Pass 414 1240 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 12 Water Unk Pass 379 1143 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 16 Water Unk Pass 429 1166 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 8 21 Water Unk Pass 422 1320 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 12 Water Unk Pass 425 1271 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 9 Water Unk Pass 483 1229 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 7 13 Water Unk Pass 299 573 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 13 Water Unk Pass 318 481 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 11 Water Unk Pass 397 690 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 10 Water Unk Pass 489 1190 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 11 Water Unk Pass 539 1631 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 9 Water Unk Pass 474 1299 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 9 15 Water Unk Pass 495 1256 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 14 Water Unk Pass Unk 813 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 16 Water Unk Pass 335 2010 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 2 12 Water Unk Pass 470 1078 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 4 11 Water Unk Pass 350 3499 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 10 Water Unk Pass 459 1769 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 14 Water Unk Pass 462 2206 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 11 Water Unk Pass 453 930 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 6 13 Water Unk Pass 440 1140 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 8 19 Water Unk Pass 420 1851 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 5 13 Water Unk Pass 540 1760 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 9 11 Water Unk Pass 360 1500 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 8 21 Water Unk Pass 354 1807 Product Unk Pass NT NT NT NT NTNT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 5 5 Water Yes PassSensor was programmed for PSD on high-liquid only, not product.Technician re-programmed for PSD on low, high, and product.Page 7 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingNT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 3 5 Water Yes PassSensor was programmed for PSD on high-liquid only, not product.Technician re-programmed for PSD on low, high, and product.NT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 3 5 Water Yes PassSensor was programmed for PSD on high-liquid only, not product.Technician re-programmed for PSD on low, high, and product.NT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 5 5 Water Yes PassSensor was programmed for PSD on high-liquid only, not product.Technician re-programmed for PSD on low, high, and product.NT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 5 Unk Water NP Pass10 2 Water NA Pass 2 2 Water Yes Pass 260 Unk Product Yes Pass NT NT NT NT NTProgrammed for "high vapor mode".NT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 5 Unk Water NP Pass3 3 Water NA Pass 2 2 Water Yes Pass 240 Unk Product Yes Pass NT NT NT NT NTProgrammed for "high vapor mode". Sensor intermittently activated"sensor out" alarm when being moved. Technician suspected ashort in wiring where cable attaches to sensor.Unk Unk Unk Unk Unk 5 14 Water Unk Pass 730 1276 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 13 21 Water Unk Pass 480 600 Product Unk Pass NT NT NT NT NTNT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTWiring malfunctioning.NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTWiring malfunctioning.NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTNT NT NT NT NT 60 5 Water Yes Pass NT NT NT NT NT NT NT NT NT NTNT NT NT NT NT NA NA NA NA NA NT NT NT NT NT NT NT NT NT NTHad 2 bad relays that had to be fixed.NT NT NT NT NT 10 5 Water Yes Pass NT NT NT NT NT 5 Unk Water NP PassUnk Unk Unk Unk Unk 10 24 Water Unk Pass 520 1769 Product Unk Pass NT NT NT NT NTNT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NT NTHad 2 bad relays that had to be fixed.Unk Unk Unk Unk Unk 13 24 Water Unk Pass 420 1978 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 18 25 Water Unk Pass 385 1470 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 12 25 Water Unk Pass 412 1920 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 12 25 Water Unk Pass 400 1695 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 15 28 Water Unk Pass 335 2281 Product Unk Pass NT NT NT NT NTNT NT NT NT NT 5 5 Water Yes Pass NT NT NT NT NT 5 5 Water Yes PassSensor was programmed for PSD on high-liquid only, not product.Technician re-programmed for PSD on low, high, and product.Unk Unk Unk Unk Unk 16 30 Water Unk Pass Unk Unk Product Unk Pass NT NT NT NT NTEmergency shut-off activated during testing, so no data was available.Unk Unk Unk Unk Unk 8 19 Water Unk Pass 420 1625 Product Unk Pass NT NT NT NT NTPage 8 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD Result Resp Rec Alarm PSD ResultLow Water Test High Water Test Product Testing Flip TestingUnk Unk Unk Unk Unk 9 19 Water Unk Pass NA NA None Unk Fail NT NT NT NT NTUnk Unk Unk Unk Unk 6 15 Water Unk Pass 600 2120 Product Unk Pass NT NT NT NT NTUnk Unk Unk Unk Unk 10 18 Water Unk Pass 600 2120 Product Unk Pass NT NT NT NT NT15 Unk Water NA Pass 5 Unk Water Yes Pass 300 Unk Product Yes Pass NT NT NT NT NT15 Unk Water NA Pass 6 Unk Water Yes Pass 390 Unk Product Yes Pass NT NT NT NT NT15 2 Water NA Pass 15 3 Water Yes Pass 270 Unk Product Yes Pass NT NT NT NT NT2 2 Product Yes Pass 2 2 Product Yes Pass 3 Unk Product Yes Pass NT NT NT NT NTProgrammed for "high vapor mode". Sensor was saturated with product vapors, so any liquid moving low or high float registreredas a product alarm.Unk Unk Unk Unk Unk 16 41 Water Unk Pass 450 1559 Product Unk Pass NT NT NT NT NTPage 9 of 9All times are recorded in seconds and heights in inches.Appendix VI, Table 3,APPENDIX VIIDiscussion of Point Liquid and Polymer Strip Discriminating SensorsAppendix VII, Discussion of Point Liquid and Polymer Strip Discriminating Sensors Page 1 of 1 

### Point Liquid and Polymer Stri p Discriminating Sensors

Point liquid type sensors use solid state electronics, which measure a particular physical property or properties of liquid that contacts the detection element. An example is capacitance change sensors, where liquid contacting the detection element acts as the di electric in a capacitor. Air (no liquid present at sensor), hydrocarbon-based liquids, and water each have distinctly different dielectric constants. A capacitance change sensor can detect this and respond di fferently when dry, or when exposed to water or hydrocarbons. Different responses from the sensor are interpreted by the control panel, which activates the appropriate alarm.

Point liquid discriminating sensors are capable of res ponding only to liquids directly in contact with the detection element. This means that product floating on water will produce a water alarm if only the water

is in contact with the detection element. The detec tion elements are usually quite small, meaning that it does not take a great deal of water to potentially mask a product release. Point liquid discriminating sensors tend to be smaller than the polymer strip type, and contain no moving parts. These attributes allow them to be installed in a variety of orienta tions, and in tight spaces (such as a tank interstice) where polymer strip sensors would not fit. Response time for this type of sensor varies by manufacturer and model, but is generally quick (less than 1 minute).

In contrast to point liquid discriminating sensors , polymer strip sensors use two detection elements combined in one housing to discr iminate between product and water * 

### . The first detection element is a

float switch or ultrasonic detector that will activate a “low liquid level” alarm when in contact with any liquid. It is located near the bottom of the sensor, and generally has a quick response time (less than 1 minute). The second detection element is a hydrocarbon-sensing cable or strip that will activate a “product” alarm when exposed to hydrocarbon-based pro duct. It will not respond to water. The cable or strip typically runs from the bottom to the top of the sensor, and response times vary between approximately 5 minutes and 20 minutes in unleaded fuel (may be 12 hours or more in diesel fuel).

It is only by combining the float or ultrasonic liquid-sensing element with the hydrocarbon-sensing element (cable or strip) that the polymer strip t ype sensor is able to discriminate between product and water. A liquid entering the area monitored by the sen sor will first contact the lowest float or ultrasonic detection element, activating a “low liquid level” alar m. This alarm alerts the UST operator that liquid is present in the monitored area. If the liquid presen t is gasoline, the hydrocarbon-sensing element will activate a “product” alarm approximately 5 to 20 mi nutes later (may be 12 hours or more for diesel fuel). In this event, the UST operator knows that product is present in the area monito red by the sensor, not just

water.

Polymer strip discriminating sensors offer the benef it of being able to detect a layer of hydrocarbon floating on water, as long as the water level is in cont act with the hydrocarbon-sensing strip. This makes them well suited for locations where water ingress is common. Many (but not all) of these sensors have an additional float or ultrasonic liquid-sensing element located at the top end of the hydrocarbon-sensing strip. This element activates a “high liquid level” alarm, which indicates that the liquid level has exceeded the height of the hydrocarbon-sensing strip. Once water has reached this level, subsequent product releases may float above and fail to contact the hydrocarbon-sensing strip, resulting in a missed detection. Polymer strip type sensors are less likely to miss a layer of product on water than point liquid discriminating sensors, but it is still a possibility that UST operators and inspectors should be aware of.

* Examples of polymer strip discriminating sensors include Emco Electronics models Q0003-002 and -003, Incon models TSP-DDS and TSP-DTS, and Veeder-R oot models 794380-320, -322, -350, and –352).