ASTM E3225-24

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: E3225 − 20 E3225 − 24
Standard Practice for
Performing a Liquid Test of Spill Prevention Equipment and
Containment Sumps Used for Interstitial Monitoring of
Piping by Visual ExaminationVisual Examination of
Containment Sumps
This standard is issued under the fixed designation E3225; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope
1.1 This practice describes a visual examination to determine if a containment sump has been compromised and to identify any
compromised components.
1.2 United States of America federal regulations found in 40 CFR 280 address inspection and testing of Spill prevention
equipment,spill prevention equipment and containment sumps are tested periodically to ensure the equipment is used for piping
interstitial monitoring. The liquid tight by using vacuum, pressure, or liquidtesting pursuant to United States of America federal
regulations found in § 40 CFR 280.35.and inspection requirements include the following:
1.2.1 Spill prevention equipment and containment sumps used for piping interstitial monitoring must be tested at least once every
three years to ensure the equipment is liquid tight by using vacuum, pressure, or liquid testing.
1.2.2 Containment sumps must be inspected annually.
1.2.3 Spill prevention equipment must be inspected every 30 days.
1.2.4 The authority having jurisdiction may have different or more frequent inspection and testing requirements.
1.3 The visual examination described in this practice addresses the inspection requirements of:
1.3.1 the annual inspection of containment sumps;
1.3.2 the 30 day walk through inspection for spill prevention equipment; and
1.3.3 the visual examination performed prior to conducting a test of the spill prevention equipment or containment sumps used for
interstitial monitoring.
1.4 This practice provides is not a liquidrecognized test by visual examination conducted by a professional inspectorto determine
if the spill prevention equipment andor containment sumps used for interstitial monitoring are liquid tight.
This practice is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct responsibility
of Subcommittee E50.01 on Storage Tanks.
Current edition approved Jan. 1, 2020Feb. 1, 2024. Published March 2020March 2024. Originally approved in 2020. Last previous edition approved in 2020 as E3225-20.
DOI: 10.1520/E3225–2010.1520/E3225–24
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E3225 − 24
1.5 The user is expected to have knowledge of UST installation procedures and UST operational, maintenance and testing
requirements of § 40 CFR 280 et seq, related to the tasks performed.
1.6 Section 6 provides the recommended minimum qualifications and educational requirements of a professionalthe inspector. The
authority having jurisdiction may have additional certification requirements.
1.7 This practice offers a set of instructions for performing one or more specific operations. This document cannot replace
education or experience and should be used in conjunction with professional judgment. Not all aspects of this practice may be
applicable in all circumstances. This ASTM standard is not intended to represent or replace the standard of care by which the
adequacy of a given professional service must be judged, nor should this document be applied without consideration of a project’s
many unique aspects. The word “Standard” in the title means only that the document has been approved through the ASTM
consensus process.
1.8 The values stated in either SI units or inch-pound units are to be regarded as standard. No other units of measurement are
included in this standard.separately as standard. The values stated in each system are not necessarily exact equivalents; therefore,
to ensure conformance with the standard, each system shall be used independently of the other, and values from the two systems
shall not be combined.
1.9 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of
regulatory limitations prior to use. Hazards known to this practice are identified in Section 8.
1.10 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
2. Referenced Documents
2.1 United States of America Environmental Protection Agency (EPA):
§ 40 CFR §280part 280 Technical standards and corrective action requirements for owners and operators of underground storage
tanks (UST)
§ 40 CFR §280.20 Performance standards for new UST systems.
§ 40 CFR §280.35 Periodic testing of spill prevention equipment and containment sumps used for interstitial monitoring of
piping and periodic inspection of overfill prevention equipment.
§ 40 CFR §280.36 Periodic operation and maintenance walkthrough inspections
2.2 United States of America Occupational Safety and Health Administration (OSHA):
§ 29 CFR §1910.120 Hazardous waste operations and emergency response
§ 29 CFR §1910.146 Permit-required confined spaces
§ 29 CFR §1910.399 Class I locations
2.3 CERCLA:
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) of 1980. §101(14)
3. Terminology
3.1 Definitions:
3.1.1 compromised, adj—a loss of structural integrity or diminished ability to perform as designed.
3.1.2 containment sump, n—a subsurface liquid tightsump container designed to contain regulated substances leaked from the
designed to be primary fuel pathliquid tight. of an underground storage tank system until the regulated substance is detected and
removed, including components commonly known as transition sumps, submersible turbine pump (STP) sumps, under dispenser
containment (UDC) sumps and piping sumps.
3.1.2.1 Discussion—
Includes components commonly known as spill containment equipment, transition sumps, submersible turbine pump (STP) sumps,
under dispenser containment (UDC) sumps and piping sumps.
Available from United States Environmental Protection Agency (EPA), William Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
http://www.epa.gov.
Available from Occupational Safety and Health Administration (OSHA), 200 Constitution Ave., NW, Washington, DC 20210, http://www.osha.gov.
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3.1.3 liquid, n—a state of matter characterized by the material flowing freely, with a definite volume but indefinite shape which
is determined by its container, and which is difficult to compress.
3.1.3.1 Discussion—
liquid does not include powders or other materials that are composed entirely of solid particles.
3.1.4 liquid test, n—the procedure to determine that a containment sump is liquid tight.
3.1.5 liquid tight, adj—the ability of sumpto contain a regulated substance leaked from the primary fuel path of a UST system
until the regulated substance is detected and removed.
3.1.6 naked eye, n—visual perception unaided by a magnifying or light-collecting optical instrument, such as a telescope or
microscope and includes vision corrected to normal acuity using corrective lenses.
3.1.7 primary fuel path, n—that portion of the UST system that routinely contains a regulated substance, including the tank,
piping, dispensers, pumps and related components.
3.1.8 professional inspector, n—an individual that satisfies independence, education, examination, experience, insurance and
licensing, certification or registration requirements of the authority having jurisdiction, to perform a liquid test of spill prevention
equipment and containment sumps used for interstitial monitoring of piping by visual examination.
3.1.8 regulated substance, n—(1) Any substance defined in section 101(14) of the Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA) of 1980 (but not including any substance regulated as a hazardous waste under subtitle
C); and (2) Petroleum, including crude oil or any fraction thereof that is liquid at standard conditions of temperature and pressure
(60 °F and 14.7 lb/in. absolute). The term regulated substance includes but is not limited to petroleum and petroleum-based
substances comprised of a complex blend of hydrocarbons, such as motor fuels, jet fuels, distillate fuel oils, residual fuel oils,
lubricants, petroleum solvents, and used oils.
3.1.9 spill prevention equipment, n—liquid tight containment sump containment basin around the fill pipe of a UST designed to
prevent release of regulated substanceUST, to the environment when the transfer hose is detached from the fill pipe, including
components commonly referred to as a catch basin, spill bucket or spill containment.
3.1.10 sump, n—when used alone meansa pit or hollow spill prevention equipmentdesigned to create working space around, or
containment sump.of below ground tank system components.
3.1.11 underground storage tank, UST, n—a tank or combination of tanks and any underground piping connected to the tank or
tanks that has at least 10 % of its combined volume underground.
3.1.12 visual examination, n—the critical naked eye observation of a containment sump by a to determine if the professional
inspectorcontainment sump to determine is capable of performing as designed or if the containment sump ishas liquidbeen
tight.compromised.
4. Summary of Practice
4.1 Perform a liquidvisual examination test according to procedures in Section 7.
4.2 Make a pass or fail determination according to the procedures in 7.5.
4.3 Report the results as in Section 9.
5. Significance and Use
5.1 All liquid and debris in a containment sump should be removed and managed properly.
5.2 Periodic testing of spill prevention equipmentLiquids andintroduced into a containment sumpssump used for interstitial
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monitoring of piping is required byfor testing purposes may come in contact with US EPAregulated substances regulation § 40
CFR §280.35.that have leaked from the primary UST system.
5.2.1 Test liquids in contact with regulated substances may require response and corrective action if leaked from a containment
sump during testing. 40 CFR §280.12 defines release as “any spilling, leaking, emitting, discharging, escaping, leaching or
disposing from an UST into groundwater, surface water or subsurface soils.”
5.2.2 For handling and disposal consideration for liquids removed from containment sumps, see Appendix X1.
5.3 The spill prevention equipmentVisual examinations andmay containmentidentify sumpscompromised used for interstitial
monitoring of piping must be tested at least once every three years to ensure the equipment isconditions that warrant repair or
response to reduce the probability of liquid tighta release byof using vacuum,regulated substance pressure, or liquid testing
according to § 40 CFR §280.35. Under this practice, an annual test is required.to the environment.
5.3.1 Visual examinations should be performed prior to the introduction of liquids in to a containment sump to reduce the potential
risk of a release of regulated substance to the environment during liquid testing methods.
5.3.2 Frequent visual examination of containment sumps between three-year test intervals is a proactive loss preventative measure
that may identify compromised equipment before the equipment fails.
5.3.3 Visual examinations do not apply vacuum, or pressure, stress to containment sump components, nor do visual examinations
introduce liquids into containment sumps which may come in contact with regulated substances that must be properly handled
pursuant to regulations of the authority having jurisdiction.
5.3 The phrase liquid tight is an ambiguous expression with the acceptable leak rate dependent upon the nature of the liquid and
the purpose of the evaluated material. This practice defines liquid tight.
5.3.1 There is no minimum containment capacity or leak rate criteria for spill prevention equipment or containment sumps used
for interstitial monitoring of piping.
5.4 Spill prevention equipment and containment sumps are designed to contain a regulated substance that is released from the
primary fuel path of a UST system including leaks that occur when the delivery hose is disconnected from the fill pipe, until the
regulated substance is detected and removed. There is no established maximum leak rate, capacity requirement or holding time.
5.5 Spill prevention equipment and containment sumps must be properly installed pursuant to § 40 CFR §280.20 in accordance
with a code of practice developed by a nationally recognized association or independent testing laboratory and in accordance with
the manufacturer’s instructions. Properly installed spill prevention equipment and containment sumps will perform as designed
unless one or more components have become compromised. Indications Many indications of component compromise that could
impact thelead to capability ofcontainment sump failure to remain liquid tight allowing a sumprelease to remain liquid tight of
liquid during a liquid test, are visually observable.
5.6 This practice is used to perform a liquid testvisual examination of containment sumps to determine if the containment sumps
are liquid tight,capable of containing a regulated substance leaked from the primary fuel path of the UST system until the regulated
substance is detected and removed.
5.7 Liquid testingVisual by visual examination is the process of using the naked eye, alone or in conjunction with various aids such
as portable lighting, camera, or mirrors, as the sensing mechanism from which a determination is made about the condition of the
containment sump being inspected.
5.8 This practice is only applicable to spill prevention equipment and containment sumps after installation testing is complete.
Properly installed spill prevention equipmentliquid tight and containment sumps will remain liquid tight unless one or more
components become compromised.
5.9 The This practice does not address all of the periodic operation and maintenance walkthrough inspections required by §40 CFR
§280.36 will not comply with this practice unless conducted by a professional inspector and all requirements of Section §280.36.7
are addressed.
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5.10 This practice is not applicable where components are not observable.
5.11 This practice does not supersede requirements developed by the manufacturer of items tested, if any requirements exist.
5.12 This practice does not supersede requirements required by the authority having jurisdiction, if any requirements exist.
6. Personnel Qualifications
6.1 Requirements—Liquid testsVisual examinations by visual examinationutilize the naked eye, alone or in conjunction w
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