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UST System Secondary Containment Testing Requirements ‐ Page 2 of 3 Secondary vapor recovery piping connected to a UST installed between July 2, 1987 and June 30, 2003, if the piping is designed so that it cannot contain liquid‐phase product. [23 CCR §2636(a)(2)] Secondary piping for a product line that has been verified as a safe suction system. [23 CCR §2636(a)(3)] C. Test Methods and Procedures 1. Secondary containment testing must be performed as follows: [23 CCR §2637(c)] o In accordance with the manufacturer's guidelines or standards.4 o Using an applicable method specified in an industry code or engineering standard if there are no manufacturer's guidelines or standards. o Using a test method approved by a state‐registered professional engineer (PE) if there are no manufacturer's guidelines, industry codes, or engineering standards. o Periodic testing must be conducted using a test procedure that demonstrates that the system performs at least as well as it did upon installation. For example, if the secondary containment system was tested upon installation by using a test method that applied a pressure of 5 p.s.i. for one hour, then the periodic test must be conducted using a method that tests the system at an equivalent pressure and for the same duration. 2. Under no circumstances may any primary containment system for flammable or combustible liquids, or secondary containment system holding a potentially explosive atmosphere, be pressurized with air. 3. When a manufacturer's installation guidelines/standards allow a choice between either pressure or vacuum testing of a tank annular space, it is recommended that vacuum testing be performed. If pressure testing is performed, the primary containment shall first be pressurized using nitrogen (or other approved inert gas) to a pressure equal to the intended secondary containment test pressure, so as to prevent undue stress to, or structural failure of, primary containment. Pressure shall be maintained on primary containment until pressure is released from the annular space at the conclusion of testing. 4. When hydrostatic testing is performed, all water must be removed from the secondary containment at the conclusion of testing. Except is cases where water will be reused for additional testing, a hazardous waste determination must be performed to determine whether or not it is hazardous based on ignitability or toxicity (e.g., Benzene contamination) and it must be disposed of properly based on the results. [HSC §25291(e), 22 CCR §66262.11] 5. Water removed from secondary containment systems, even if uncontaminated by hazardous materials, must not be disposed of to the storm water system. [Nonpoint Source (Urban Runoff) Ordinances] 4 Some manufacturers’ test procedures allow for a “Pass” provided that a specified drop in pressure or vacuum is not exceeded. State law requires that UST systems installed after January 1, 1984 and prior to July 1, 2003 be product‐tight [HSC §25291(a)(1)], and that UST systems installed on or after July 1, 2003 be both product‐tight and vapor‐tight [HSC §§25292.1(a), 25292.1(c)(1), 25290.2(a), and 25290.2(c)(1)]. When statute and regulations conflict, requirements of statute prevail. Unidocs Member Agency interpretation is that the regulatory wording of 23 CCR §2637(c) is superseded by the product‐tight and vapor‐tight requirements of HSC, so no drop in pressure or vacuum is allowed for a passed secondary containment test.