Owners and operators of regulated underground storage tanks (USTs) on tribal lands must comply with the federal UST regulation. This compliance assistance brochure highlights tips to help you manage your piping release detection. Note: This document is a resource to promote compliance and does not replace the federal UST regulation. This brochure is one in a series of EPA compliance assistance brochures designed to help owners and operators in Indian country comply with the federal UST regulation. Other brochures focus on implementation, compatibility, spill buckets, overfill protection, recordkeeping and notification, financial responsibility, insurance, and tank release detection. P Inspect oEPA Office of Underground Storage Tanks www.epa.gov/ust July 2018 EPA-510-F-18-001 Compliance Assistance In Indian Country ------- RELEASE DETECTION Piping elease detection is a method or combination of methods designed to heip quickly detect releases from underground piping. What type of release detection must you use? A line leak detector must be installed on your pres- surized piping and must be tested annually. Also, if your pressurized piping was installed or replaced on or before April 11, 2016, you must use one of the following release detection methods: * Annual tightness test ^ Monthly monitoring using either * Interstitial monitoring for double-walled piping * Continuous in-tank leak detection * Vapor monitoring * Groundwater monitoring * Statistical inventory reconciliation ^ Other methods approved by the implementing agency If your pressurized piping was installed or replaced after April 11, 2016, your system must be secondarily contained and you must use interstitial monitoring. . What type of release detection can you use for suction piping? Release detection is not required if the suction piping: Operates at below atmospheric pressure f Sloped so its contents drain back into the tank, and ^ Only one check valve directly below the dispenser pump If your suction piping does not exactly match the characteristics above, you must use one of the monthly methods used for pressurized piping, or conduct a tightness test at least once every three years. If you use vapor monitoring or groundwater monitoring, you must keep records of a site assessment showing that the monitoring system is set up properly. Suction piping system What should you do to ensure your release detection device is working properly? If you use a: Control panel *** Check your printout * What does the printout show? Is the system working properly or are there problems that need to be addressed? MUM DD, YYYY HK:MM XM Q 1:UNLEADED REG LINE 3.0 GAL/HR RESULTS: xm| pass ] NUMBER OP TESTS PASSEI PREV 24 HOURS : 12j SINCE MIDNIGHT : 81 0.20 GAL/HR RESULTS: 0.10 GAL/HR RESULTS: Piping leak test results ALARM HISTORY REPORT — SENSOR hLhRH — L1:DISP 12 DISPSUMP |FUEL ALARM | JUL 'Hi, W 10112 PH I FUEL Ml I S? 20. 2005 8:27 PH Ifiifi urn I FI8 21. 2005 5:03 PM LIQUID STATUS MUM DD, YYYY HH;W XM L 1 : UNLEAD2D WJNULAR P50B tPRHLI L 2 : S'uPtH MM ISENSOR KORMALI Sump sensor alarm history Sump sensor status report Immediately respond to and investigate any con- trol panel alarms or flashing lights. Make sure alarms function properly. Releases may go undetected if you ignore or disable the alarms. Containment sump Check your sump * Is a sensor present? * Is the sensor positioned correctly? * Is there any liquid or product present? * Does the lid have a tight seal and is it securely fastened? * Is the sump damaged? A damaged sump will not hold product if a release occurs. / Control panel indicator lights Tank top sump with double- walled piping and liquid sensor Containment sumps that are part of the piping Interstitial monitoring system must be tested at least once every three years for liquid tightness. Tank top sump full of liquid How do you avoid common piping release detection problems? Line leak detectors (LLD) «*" Make sure the LLD is installed or functions correctly Test annually with simulated leak at three gallons per hour at 10 psi line pressure w Make sure the LLD is programmed or properly connected Submersible turbine pump without a LLD installed Electronic LLD Mechanical LLD Sensors w Make sure sensors are present and functioning ^ Make sure sensors are properly installed and test annually Tank top sump sensor installed too high Moved sensor cannot detect liquid Tightness Testing Test every three years including suction systems that do not meet the exemption requirements Conduct an annual line test for pressurized piping Recordkeeping w Keep records of annual tightness tests Keep records of annual release detection equipment tests for LLD and sensors «*" Keep release detection performance claims or repair and maintenance records *" Keep records of the 30-day visual equipment inspection or annual walkthrough inspection Keep site assessment records for vapor and groundwater monitoring For more information on piping release detection, see EPA's Release Detection For Underground Storage Tanks and Piping: Straight Talk on Tanks or order free copies by calling (800) 490-9198. ------- |