Several new requirements effective October 13, 2018 will have a big impact on UST owner and operators. Over the years, changes to the Illinois OSFM Regulations for USTs have been difficult to keep up with.
Requirement to test ALL spill buckets.
Requirement to test ANY containment sumps USED FOR INTERSTITIAL MONITORING of PIPING.
Requirement to inspect ALL overfill prevention equipment.
Requirement to complete Annual Leak Detection Certification.
Requirement to document compatibility for ALL blended fuel USTs throughout the UST system.
Requirement for A/B OPERATORS and or CONTRACTORS to conduct Periodic Operation & Maintenance Walkthrough Inspections at ALL Regulated facilities: 30 day and annual.
Requirement to test all Spill Buckets and any Containment Sumps used for Interstitial Monitoring of Piping. The options are “either/or.”
OPTION 2: 175.405(b)(2): Equipment (spills/sumps) must be tested every 3 years. Test may be a hydrostatic test, a vacuum test, a pressure test or a low level positive shutdown test (for qualifying piping sump installations only).
Testing must follow either manufacturer’s instructions or requirements as defined by the implementing agency.
The first tests must be done by 10/13/2018.
For systems installed after 10/13/2015, requirements already apply. OSFM has required the containment test to be done at installation of new sumps for years.
OPTION 1: 175.405(b)(1): Alternative to 3 year testing if done correctly.
Equipment (spills/sumps) must be double walled.
This option requires monitoring of the equipment interstice, and there must be a record of the interstice being monitored every 30 days.
The records of that monitoring must be kept and be available for inspection for 3 years.
Failure to have complete documentation will result in performing a containment test.
Requirement to Test ALL Spill Buckets (175.405)
Illinois has over 19,000 regulated USTs at nearly 7,000 active facilities.
Each of these tanks has spill containment, usually and preferably a spill bucket.
Failure rates > 65% were experienced in CA when sump testing was first required 10 years ago.
We could see over 12,000 spill bucket failures in the next 2 years.
On the plus side, Spill Buckets will be comparatively easy to test and replace if necessary.
Hydrostatic testing will require significantly less water for spill buckets compared to piping sumps.
Penetrations are minimal.
Some contractors offer vacuum testing as an alternative to hydrostatic testing.
We will now allow stainless steel “drop-in” spill buckets, and allow them to be as small as 3.5 gallon capacity. This is being done to allow an additional option we can live with. 3.5 gallons will fit inside of 90%+ of existing models, per one manufacturer.
“Multiport” Fills may have sensors in the containment. These are not interstitial sensors, since there is a drop tube and a vapor port in the containment, not pressurized, double wall product piping.
Only the spill bucket in the multiport containment gets tested if the vapor port and drop tube each has its own individual bucket.
However, if both the vapor port & the drop tube are in a single containment, the containment is the spill bucket, and it must be tested.
Note: A spill bucket inside of another containment is not a double wall spill bucket, although technically it is secondarily contained.
Illinois OSFM Regulations for USTs
Illinois OSFM Regulations for USTs
175.410: Requirement to Test ANYContainment Sumps USED FOR INTERSTITIAL MONITORING of PIPING: What Qualifies for Testing?
Single wall piping in a sump, whether there is a sensor there or not, does not qualify. There is no interstice to monitor. Therefore the sensor is not an interstitial monitoring sensor. These can be changed in our equipment list to “Sump Sensor — Nonregulated” (available soon). Making this change will require an UPG permit.
Double wall piping in a sump which was installed prior to 2/1/2008 without any sensors in the sumps does not qualify for 3 year testing, and is legally grandfathered.
Double wall piping in a sump which was installed prior to 2/1/2008 with a sensor in the sump does qualify for 3 year testing in Illinois.
Any double wall piping in a sump which was installed after 2/1/2008 must have a sensor in the sump and obviously does qualify.
Note: Single wall piping run inside a chase may be secondarily contained, but it is not double wall piping. These entries will be corrected as they are encountered.
Requirement to Test ANYContainment Sumps USED FOR INTERSTITIAL MONITORING of PIPING: Testing Options (175.410(l))
Hydrostatic Test for Spill Buckets and Piping Containment Sumps
This is the test done now.
We adapted the PEI RP1200 method to our new requirements:
Spill Buckets are filled to within 1.5” of the top
Piping Containment Sumps are filled to a height that covers the highest penetration or sidewall seam by 4”.
Duration of test is ½ hour, with a drop of less than 1/8” considered passing.
Vacuum Testing and Pressure Testing will also be accepted, although these will be unlikely to be practicable for piping containment sumps.
And then there’s the Low Level Positive Shutoff Test.
This is not for installs or repairs or NOVs – those all require hydrostatic testing.
There are listed conditions which must be met:
Positive STP shutdown must be there and be verified as working.
Sumps must pass visual inspection by contractor for structural soundness and integrity.
Sumps cannot be found to be full of water/debris or with sensors in alarm or with sensors pulled up.
Testing must be performed following sensor manufacturer’s specifications.
Discriminating Sensors must be tested in manufacturer specified “test liquid” and must shut down the STP on activation. Discriminating Sensors with water alarms must shut down the dispenser or the STP.
For a more detailed explanation of the Illinois OSFM Regulations for USTs, please contact the professionals at Eagle Environmental Consultants.
