California Code of Regulations › Title 23 - Waters › Division 3 - State Water Resources Control Board and Regional Water Quality Control Boards › Chapter 16 - Underground Tank Regulations › Appendix IV - Evaluation Procedure for Leak Detection Equipment

Current through Register 2024 Notice Reg. No. 28, July 12, 2024
Leak detection equipment can be evaluated for performance in
				  accordance with one of the following three evaluation procedures:
1. EPA Standard Test Procedures
EPA has developed a series of standard test procedures that
				  cover most of the methods commonly used for underground storage tank leak
				  detection. These include:
a. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Volumetric Tank Tightness Testing Methods"
b. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Nonvolumetric Tank Tightness Testing Methods"
c. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Automatic Tank Gauging Systems"
d. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Statistical Inventory Reconciliation Methods"
e. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Vapor-Phase Out-of-Tank Product Detectors"
f. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Liquid-Phase Out-of-Tank Product Detectors"
g. "Standard Test Procedures for Evaluating Leak Detection
				  Methods: Pipeline Leak Detection Systems"
Each test procedure provides an explanation of how to conduct
				  the test, how to perform the required calculations, and how to report the
				  results. The results from each standard test procedure provide the information
				  needed by tank owners and operators to determine if the method meets the
				  regulatory requirements.
EPA standard test procedures must be conducted by an
				  independent third party under contract to the manufacturer in order to prove
				  compliance with the regulations. Independent third-parties may include
				  consulting firms, test laboratories, not-for-profit research organizations, or
				  educational institutions with no organizational conflict of interest. In
				  general, evaluations are more likely to be fair and objective the greater the
				  independence of the evaluating organization.
2. National Consensus Code or Standard
A second way for a manufacturer to prove the performance of
				  leak detection equipment is to have an independent third party evaluate the
				  system following a national voluntary consensus code or standard developed by a
				  nationally recognized association (e.g., ASTM, ASME, ANSI, etc.). Throughout
				  the technical regulations for underground storage tanks, EPA has relied on
				  national voluntary consensus codes to help tank owners decide which brands of
				  equipment are acceptable. Although no such code presently exists for evaluating
				  leak detection equipment, one is under consideration by the ASTM D-34
				  subcommittee. Guidelines for developing these standards may be found in the
				  U.S. Department of Commerce "Procedures for the Development of Voluntary
				  Product Standards" (FR, Vol. 51, No. 118, June 29, 1986) and OMB Circular No.
				  A-119.
3. Alternative Test Procedures Deemed Equivalent to
				  EPA's
In some cases, a specific leak detection method may not be
				  adequately covered by EPA standard test procedures or a national voluntary
				  consensus code, or the manufacturer may have access to data that makes it
				  easier to evaluate the system another way. Manufacturers who wish to have their
				  equipment tested according to a different plan (or who have already done so)
				  must have that plan developed or reviewed by a nationally recognized
				  association or independent third-party testing laboratory (e.g. Factory Mutual,
				  National Sanitation Foundation, Underwriters Laboratory, etc.). The results
				  should include an accreditation by the association or laboratory that the
				  conditions under which the test was conducted were at least as rigorous as the
				  EPA standard test procedure. In general, this will require the
				  following:
a. The evaluation tests the system both under the no-leak
				  condition and an induced-leak condition with an induced leak rate as close as
				  possible to (or smaller than) the performance standard. In the case of tank
				  testing, this will mean testing under both 0.0 gallon per hour and 0.10 gallon
				  per hour leak rates. In the case of ground water monitoring, this will mean
				  testing with 0.0 and 0.125 inch of free product.
b. The evaluation should test the system under at least as
				  many different environmental conditions as the corresponding EPA test
				  procedure.
c. The conditions under which the system is evaluated should
				  be at least as rigorous as the conditions specified in the corresponding EPA
				  test procedure. For example, in the case of volumetric tank tightness testing,
				  the test should include a temperature difference between the delivered product
				  and that already present in the tank, as well as the deformation caused by
				  filling the tank prior to testing.
d. The evaluation results must contain the same information
				  and should be reported following the same general format as the EPA standard
				  results sheet.
e. The evaluation of the leak detection method must include
				  physical testing of a full-sized version of the leak detection equipment, and a
				  full disclosure must be made of the experimental conditions under which: (1)
				  the evaluation was performed, and (2) the method was recommended for use. An
				  evaluation based solely on theory or calculation is not
				  sufficient.
1. Renumbering
				  of former Appendix IV to Appendix III and renumbering of former Appendix V to
				  Appendix IV filed 4-5-94; operative 5-5-94 (Register 94, No. 14). For prior
				  history, see Register 92, No. 43.