Inspection, Testing and Maintenance
Inspection, Testing and Maintenance (Domain 6) tests cadence and acceptance criteria: what is tested, how often, what counts as a pass, and what record proves it. Federal requirements in 40 CFR 280.35 and 280.36 set the floor, and PEI RP1200 describes how to perform the tests.
Periodic testing cadence
- Release detection equipment: tested at least annually.
- Spill prevention equipment (spill buckets): tested at least every 3 years for liquid tightness.
- Containment sumps: tested at least every 3 years.
- Overfill prevention equipment: inspected and tested at least every 3 years.
- Walkthrough inspections: at least every 30 days, covering release detection, spill prevention and overfill.
- Line leak detectors: annual 3 gph test in addition to ongoing monitoring.
Condition items that fail most often
- Spill bucket with a stuck drain valve, standing water, or a missing cap gasket.
- Sump boots torn, sensors coated, or product present.
- Dispenser hose bulging, or a breakaway that has already separated.
- ATG probe fouled, or high-level alarm setpoints changed without documentation.
Worked example
An annual line leak detector test is run on a pressure line. The detector must detect a 3 gph leak at 10 psi within one hour and restrict or shut off flow. If it passes only when the bypass is manually held, it fails: the bypass is a test aid, not a repair. Record the test pressure, the induced leak rate, the time to alarm and the technician's certification.
Distinguish the numbers
- 0.1 gph is the release-detection sensitivity for tank tightness testing and monthly monitoring.
- 3 gph is the line leak detector threshold; it protects against catastrophic line releases, not slow ones.
- 0.2 gph is the sensitivity statistical inventory reconciliation must achieve; the state rule governs which method is allowed.
Traps
- Confusing the annual release-detection test with the 3-year sump test.
- Passing a sump test with water or product still in the sump.
- Recording a pass without calibration data or the induced leak rate.
- Skipping post-repair testing after replacing a sump boot.