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It has been established that the obligation of com- OPTION A ! pliance with the appropriate regulations covering USTs is the owners, with the following guidelines BASIC FUNCTION EVALUATION in place in reference to LLDs. Testing Red Jacket Mechanical ! EPA regulations require that the LLD be installed Line Leak Detectors with the and operating, capable of detecting a catastrophic Apparatus to verify Qperation (AVO) leak and tested annually in accordance with the ! manufacturer's requirements.The manufacturer's Option A: How to verify operation of Red Jacket requirements and procedures for annual testing of mechanical leak detectors.The apparatus to verify Red Jacket LLDs are covered in Option A, Form operation(AVO)will be required for this procedure. ! RJ-21 and Option B, Form RJ-20. While some It can be constructed from readily available parts. regulatory bodies have, EPA has not issued guide- See material list and assembly, p. 5. See pages 6 lines as to when LLDs are to be replaced based on and 7 for an explanation of Th ten Leak quantitative performance. They state that annual Detector Test. ! quantitative performance tests of LLDs installed in the field are not required by EPA standards.Itis I. INSTALLATION OF THE AVO suggested to check with state and local authorities ! for any requirements that may differ from those of Disable power to submersible thebefore attempting to con- nect AVO to impact valve. Fail- Based on the above and other pertinent factors,it ure to do so may cause an acci- is our opinion that the UST owner is the best dental discharge of pressurized equipped to assess their situations and therefore to gasoline that may result in per. make the decision as to when subject LLD is to be sonal injury, fire or explosion. replaced. We do not consider it prudent as the Tag or lock out submersible manufacturer to make that determination. pump breaker to avoid pump We do urge that if,after evaluation in the pumping being accidentally turned on. ! system,subject LLD is not demonstratingthecapa- 1. CarefaUybleed anyresidual pressure present bility of reacting to a leak of 5 GPH or greater, in the system, catching the fluid discharged in serious assessment be made of the entire pumping a suitable container.Ifthe test port of the shear system and of replacement of the LLD versus con- valve is used for this purpose,see the following tinued use. 097M in step 2 first. We have no control,influence or participation with reference to IM= Use a suitable container to re- the design,operation or quality ceive product throughout this of any mechanical leak detec- procedure. Plastic containers tors other than those manufac. may store static electricity which ' tured and marketed by The could discharge,causing severe Marley Pump Company under personal injury, fire and/or ex. the Red Jacket petroleum equip- plosion.Use onlyapprovedmetal ! ment identification. We, there- type containers. Use adequate fore, do not advise or condone absorbants to catch any spillage use of the information, proce. and avoid ground contamina- ! dures or equipment covered in tion. this or any other publication is- sued by The Marley Pump Com- 2. Install the AVO in the dispenser shear valve as ! pany for any equipment other shown in Figure 1. than Red Jacket petroleum equipment. ! For additional assistance with regard to the above or any,Red Jacket petroleum equipment,call us at 1-913-831-5700 or our fax number is 913-831-5172. ! 2