Inspecting and Testing Secondary Containment Sumps
Written by: Brian Pottebaum, Director of Training Services
This is part two of our series on secondary containment systems. To read about the different types of secondary containment and the steps to properly operate and maintain them, click here: Understanding Secondary Containment Systems - PMMIC.
Adding another layer of protection to your tank is advantageous and that is exactly what secondary containment can provide. However, to provide adequate protection, secondary containment not only must be properly maintained, but frequently tested and inspected.
Tanks and product piping are now constructed with two layers; primary and secondary. Industry refers to that as a double wall system. In addition to these double wall systems, regulations require secondary containment sumps under dispensers and at piping transitions, such as the tank-top connection.
For these systems to be effective, they must be properly maintained. This includes cleaning, inspections, and testing. If there is any liquid, whether it is fuel or water, it must be cleaned out immediately. However, inspections and testing still cause confusion for some operators.
The containment system must be liquid-tight, no liquid in and no liquid out. The containment must also remain clean and dry, and sensing devices must be properly placed at the lowest containment level. All sensor alarms must be addressed immediately. Regulated substances spilled into any spill catchment basin, piping sump, transition/intermediate piping sump, or under-dispenser containment must be immediately removed.
What inspections are required?
Every 30 Days, you should be checking or monitoring the secondary containment for any indication of a leak in the system. This must document “normal status” of the system with a printout (liquid sensor status report) or record of visual inspection. This is the method of monthly line leak detection for newer installations, so make sure you always maintain 12 months of records in your file. This should be completed as part of your 30-day walkthrough inspections.
√ File “sensors status” printout or log visual inspection of containment sumps.
Annually, a knowledgeable person must complete walkthrough inspections of the piping containment sumps. The owner or a facility employee can conduct this inspection, or it can be contracted with another company. These inspections must document that the containment sumps are clean and intact. PMMIC provides this annual service to all insured facilities at no additional cost.
√ Complete and File the annual walkthrough inspection of all containment sumps.
Every 2 Years (Iowa only), you must hire an Iowa-licensed installer or Iowa-certified compliance inspector to perform a “visual” inspection of each secondary containment sump. This is generally completed as part of the UST Compliance Inspection. The inspection report must be filed with the DNR and readily available along with your monitoring records. Sumps and basins must be intact (no cracks or perforations) and liquid-tight, including sides and bottom. PMMIC is also providing this service to all insured facilities at no additional cost.
√ Complete and File the regulatory compliance inspection of your UST system, which includes the visual inspection of the secondary containment system and monitoring equipment.
What testing is required?
Annually, the sensing device (if done electronically) must be tested for proper setup and operation. All testing should be done in a way that is supported by the equipment manufacturer. All liquid sensors must be inspected, tested and returned to the proper location in the containment areas.
√ Complete and File the liquid sensor functionality test report.
Every 3 Years, Secondary containment sumps used for interstitial monitoring of piping shall be tested upon installation or repair and every three years thereafter. The containment sumps used for interstitial monitoring of piping must be tested at least once every three years in accordance with an industry standard or manufacturer specifications to ensure the equipment is liquid tight by using vacuum, pressure, or liquid testing. A knowledgeable owner or a facility employee can conduct these three-year liquid tightness tests, however it is typically conducted by an outside service company with trained individuals.
√ Complete and File the secondary containment sump tightness test report.