ASTM E2733-10(2015)

Standard Guide for Investigation of Equipment Problems and Releases for Petroleum Underground Storage Tank Systems

SIGNIFICANCE AND USE
4.1 This guide may be used in the investigation of underground storage tank systems for equipment problems in a wide variety of applications. Use of this guide is voluntary. It is intended to assist users who want to investigate equipment failures and malfunctions.  
4.2 The following groups of users may find the guide particularly helpful:  
4.2.1 Storage tank system designers;  
4.2.2 Storage tank installers;  
4.2.3 Storage tank maintenance contractors;  
4.2.4 Storage tank removal contractors;  
4.2.5 Storage tank inspectors;  
4.2.6 Federal, state or local regulators, including departments of health, departments of environmental protection, and fire departments;  
4.2.7 Storage tank release detection installers;  
4.2.8 Storage tank testers;  
4.2.9 Petroleum release remediation consultants;  
4.2.10 Storage tank equipment manufacturers;  
4.2.11 Insurance adjusters;  
4.2.12 Storage tank owners and operators;
4.2.12.1 Retail fuel service station owners and operators;
4.2.12.2 Small businesses or enterprises;
4.2.12.3 Service industries;
4.2.12.4 Waste managers, including liquid and solid waste haulers, treatment, recycling, disposal and transfer;
4.2.12.5 Non-regulatory government agencies, such as the military;
4.2.12.6 Specific industrial sectors such as dry cleaners, printers, photo processors, laboratories; and  
4.2.13 Consultants, auditors, inspectors, and compliance assistance personnel.  
4.3 This guide is intended to assist in the development of protocols for the investigation of a malfunction or failure of storage tank systems and the implementation of said protocols. This guide outlines steps that may be necessary and include, but are not limited to initial evaluation of the UST system to determine the malfunction(s); preparation of samples of failed equipment for laboratory analysis; and document the investigation. The guide provides a series of investigation options on which the user may design failure investigation prot...
SCOPE
1.1 Overview—This guide is an organized collection of information and series of options for industry, regulators, consultants and the public, intended to assist with the development of investigation protocols for underground storage tank facilities in the United States. While the guide does not recommend a specific course of action, it establishes an investigation framework, and it provides a series of techniques that may be employed to: identify equipment problems; in some cases prepare samples of failed equipment for laboratory analysis; and document the investigation. The guide includes information on methods of investigation, documentation, taking samples of problem equipment; preservation of equipment samples; chain of custody; storage; shipping; working with equipment manufacturers; and notification of regulators and listing laboratories. The goal in using the guide is to identify the appropriate level of investigation and to gather and preserve information in an organized manner, which could be used in the future to improve system design or performance. While this guide may act as a starting point for users with limited experience in failure investigation, the user is encouraged to consult with failure analysis experts for specific investigation procedures that may be needed for certain equipment and the investigation should be conducted by a qualified professional. As users develop their specific investigation protocols, they may find that the investigations can be streamlined for certain types of facilities.  
1.2 Limitations of This Guide:  
1.2.1 Given the variability of the different investigators that may wish to use this guide and the different types of facilities and failures that will be investigated, it is not possible to address all the relevant standards that might apply to a particular investigation. This guide uses generalized language and examples to guide the user. If it is not clear to the user ...

General Information

• Status: Historical
• Publication Date: 31-Mar-2015
• ICS: 75.200 - Petroleum products and natural gas handling equipment
• Technical Committee: E50 - Environmental Assessment, Risk Management and Corrective Action
• Drafting Committee: E50.01 - Storage Tanks

Relations

• Replaced By: ASTM E2733-23 - Standard Guide for Investigation of the Source and Cause of Releases from Underground Storage Tank Systems
• Effective Date: 01-Sep-2023
• Refers: ASTM E1188-11 - Standard Practice for Collection and Preservation of Information and Physical Items by a Technical Investigator
• Effective Date: 01-Sep-2011
• Refers: ASTM F1127-07 - Standard Guide for Containment of Hazardous Material Spills by Emergency Response Personnel
• Effective Date: 01-Nov-2007
• Refers: ASTM F1127-01(2007) - Standard Guide for Containment by Emergency Response Personnel of Hazardous Material Spills
• Effective Date: 01-Apr-2007
• Refers: ASTM E1188-05 - Standard Practice for Collection and Preservation of Information and Physical Items by a Technical Investigator
• Effective Date: 01-Apr-2005
• Refers: ASTM F1127-01 - Standard Guide for Containment by Emergency Response Personnel of Hazardous Material Spills
• Effective Date: 10-Oct-2001
• Refers: ASTM F1127-88(1996) - Standard Guide for Containment by Emergency Response Personnel of Hazardous Material Spills
• Effective Date: 10-Oct-2001
• Refers: ASTM E1188-95 - Standard Practice for Collection and Preservation of Information and Physical Items by a Technical Investigator
• Effective Date: 01-Jan-1995

Standards Content (Sample)

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.
Designation: E2733 − 10 (Reapproved 2015)
Standard Guide for
Investigation of Equipment Problems and Releases for
Petroleum Underground Storage Tank Systems
This standard is issued under the fixed designation E2733; 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.
INTRODUCTION
This guide provides a framework for the development of procedures and directions for the
investigation of equipment problems associated with petroleum underground storage tank (UST)
systems and releases. It gives the user practical suggestions of how to investigate equipment and
installation problems, document findings, and in some cases prepare samples of failed equipment for
laboratory analysis. Use of this guide may result in the identification of equipment and installation
problems that can be corrected in future tank system designs and equipment maintenance programs to
prevent releases to the environment.
1. Scope protocols, they may find that the investigations can be stream-
lined for certain types of facilities.
1.1 Overview—This guide is an organized collection of
information and series of options for industry, regulators,
1.2 Limitations of This Guide:
consultants and the public, intended to assist with the devel-
1.2.1 Given the variability of the different investigators that
opmentofinvestigationprotocolsforundergroundstoragetank
may wish to use this guide and the different types of facilities
facilities in the United States. While the guide does not
and failures that will be investigated, it is not possible to
recommend a specific course of action, it establishes an
address all the relevant standards that might apply to a
investigation framework, and it provides a series of techniques
particular investigation. This guide uses generalized language
that may be employed to: identify equipment problems; in
and examples to guide the user. If it is not clear to the user how
some cases prepare samples of failed equipment for laboratory
to apply standards to their specific circumstances, it is recom-
analysis; and document the investigation. The guide includes
mended that users seek assistance from qualified professionals.
information on methods of investigation, documentation, tak-
ing samples of problem equipment; preservation of equipment 1.2.2 This guide does not address safety issues associated
samples; chain of custody; storage; shipping; working with
with the investigation, taking samples and storing equipment.
equipment manufacturers; and notification of regulators and
users are cautioned to exercise proper care in handling equip-
listing laboratories. The goal in using the guide is to identify
ment that was in contact with flammable and combustible
the appropriate level of investigation and to gather and
liquids and vapors. Some of the activities described in this
preserve information in an organized manner, which could be
guide may be subject to OSHA (Occupational Safety and
used in the future to improve system design or performance.
Health Administration) regulations or may only be conducted
While this guide may act as a starting point for users with
by individuals with appropriate HAZWOPER (Hazardous
limited experience in failure investigation, the user is encour-
Waste Operations and Emergency Response) training certifi-
aged to consult with failure analysis experts for specific
cations recognized by federal and state regulatory authorities,
investigation procedures that may be needed for certain equip-
such as HAZWOPER training.
ment and the investigation should be conducted by a qualified
1.2.3 This guide does not address laboratory investigations
professional. As users develop their specific investigation
of material properties and detailed failure analysis.
1.2.4 This guide does not cover underground storage tank
systems storing liquefied petroleum gas (LPG).
ThisguideisunderthejurisdictionofASTMCommitteeE50onEnvironmental
Assessment, Risk Management and CorrectiveAction and is the direct responsibil-
1.2.5 This guide does not replace state-required closure
ity of Subcommittee E50.01 on Storage Tanks.
assessments and investigations. Requirements vary from state
Current edition approved April 1, 2015. Published May 2015. DOI: 10.1520/
E2733–10R15. to state and often include specific sampling requirements.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2733 − 10 (2015)
1.3 The values stated in inch-pound units are to be regarded 4. Significance and Use
as standard. No other units of measurement are included in this
4.1 This guide may be used in the investigation of under-
standard.
ground storage tank systems for equipment problems in a wide
variety of applications. Use of this guide is voluntary. It is
2. Referenced Documents
intended to assist users who want to investigate equipment
2.1 ASTM Standards:
failures and malfunctions.
E1188 Practice for Collection and Preservation of Informa-
4.2 The following groups of users may find the guide
tion and Physical Items by a Technical Investigator
particularly helpful:
F1127 Guide for Containment of Hazardous Material Spills
4.2.1 Storage tank system designers;
by Emergency Response Personnel
4.2.2 Storage tank installers;
2.2 Other Standards:
4.2.3 Storage tank maintenance contractors;
STD 2015 Requirements for Safe Entry and Cleaning of
4.2.4 Storage tank removal contractors;
Petroleum Storage Tanks, 6th Edition—August 2001
4.2.5 Storage tank inspectors;
RP2016 Guidelines and Procedures for Entering and Clean-
4.2.6 Federal, state or local regulators, including depart-
ing Petroleum Storage Tanks, 1st Edition—August 2001
ments of health, departments of environmental protection, and
PEI/RP 100 Recommended Practices for Installation of Un-
fire departments;
derground Liquid Petroleum Storage Systems, Petroleum
4.2.7 Storage tank release detection installers;
Equipment Institute (PEI)
4.2.8 Storage tank testers;
NFPA 30 Flammable and Combustible Liquids Code
4.2.9 Petroleum release remediation consultants;
2.3 Federal Regulations:
4.2.10 Storage tank equipment manufacturers;
49 CFR 172 Hazardous Materials Table, Special Provisions,
4.2.11 Insurance adjusters;
Hazardous Materials Communications, Emergency Re-
4.2.12 Storage tank owners and operators;
sponse Information, and Training Requirements
4.2.12.1 Retail fuel service station owners and operators;
29 CFR 1910.146 Occupational Safety and Health
4.2.12.2 Small businesses or enterprises;
Standards, Subpart J, General Environmental Controls,
4.2.12.3 Service industries;
Permit-required Confined Spaces
4.2.12.4 Waste managers, including liquid and solid waste
haulers, treatment, recycling, disposal and transfer;
3. Terminology
4.2.12.5 Non-regulatory government agencies, such as the
3.1 Definitions:
military;
3.1.1 equipment problems or problem equipment—any
4.2.12.6 Specific industrial sectors such as dry cleaners,
failure, malfunction, or other issue that has resulted in abnor-
printers, photo processors, laboratories; and
mal equipment condition or operation or that has resulted in a
4.2.13 Consultants, auditors, inspectors, and compliance
release or suspected release.
assistance personnel.
3.1.2 release prevention—activities that reduce the risk of
4.3 This guide is intended to assist in the development of
human and environmental exposure to petroleum or hazardous
protocols for the investigation of a malfunction or failure of
substances. In the United States, underground storage tank and
storage tank systems and the implementation of said protocols.
toxic use reduction regulations are examples of such require-
This guide outlines steps that may be necessary and include,
ments.
but are not limited to initial evaluation of the UST system to
3.1.3 underground storage tank—a tank and any under-
determine the malfunction(s); preparation of samples of failed
groundpipingconnectedtothetankthathasatleast10 %ofits
equipment for laboratory analysis; and document the investi-
combined volume underground.
gation. The guide provides a series of investigation options on
which the user may design failure investigation protocols. The
3.1.4 waste—discarded solid or liquid materials that may be
guide describes common investigation techniques in the order
hazardous to public health or the environment. Solid and
in which they might be employed in an investigation.
hazardous waste require controls on handling, transport, stor-
age treatment, and disposal.
4.4 A user may elect to utilize this guide for a number of
reasons, which include, but are not limited to:
4.4.1 To differentiate new releases from new discovery of
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
old releases;
contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
4.4.2 To establish malfunction and failure rates of various
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website. storage tank equipment components;
Available from American Petroleum Institute (API), 1220 L. St., NW,
4.4.3 To determine expected life spans of various storage
Washington, DC 20005-4070, http://www.api.org.
tank equipment components;
Available from Petroleum Equipment Institute (PEI), P. O. Box 2380, Tulsa,
4.4.4 To identify opportunities for improving the perfor-
OK 74101-2380, http://www.pei.org.
Available from National Fire Protection Association (NFPA), 1 Batterymarch
mance and reliability of storage tank equipment;
Park, Quincy, MA 02169-7471, http://www.nfpa.org.
4.4.5 To focus inspection and maintenance efforts on those
AvailablefromU.S.GovernmentPrintingOfficeSuperintendentofDocuments,
portions of the tank system that are most prone to malfunction
732 N. Capitol St., NW, Mail Stop: SDE, Washington, DC 20401, http://
www.access.gpo.gov. and failure;
E2733 − 10 (2015)
4.4.6 To identify those components of the storage tank 5.2 General Records—Gathering and reviewing records
system that require more frequent maintenance; prior to the physical investigation may help focus the investi-
gation and make the investigation run smoothly. Reviewing
4.4.7 To reduce remediation and equipment replacement
recordsfromthefollowingcategoriesmayhelpinformtheuser
costs;
whattypesofequipmenttoexpect,wheretheequipmentcanbe
4.4.8 To prevent petroleum releases;
found, the repair and maintenance history and prior releases.
4.4.9 To identify those conditions that may cause or con-
These records may be in the possession of the owner(s) of the
tribute to the deterioration or cause the malfunction and failure
petroleum underground storage tank system; a third party
of various components of the UST system; and
consultant or maintenance contractor; or one or more regula-
4.4.10 To comply with environmental regulations that
tory entities. The user may find that it is beneficial to organize
require the investigation of release detection alarms and the
the records and bring them to the field investigation for
source of releases.
reference.
4.5 This guide may be used to establish a framework, which
5.2.1 Equipment purchase records.
pulls together the common approaches to investigation. The
5.2.2 Installation records:
framework will allow the user to establish an investigation
5.2.2.1 “Record” or “as-built” drawings andor site plans;
protocol to meet their specific requirements. Specific user
5.2.2.2 Installation check lists;
requirementswillvarydependinguponthepurposesofthedata
5.2.2.3 Pre-operation leak checks;
collectionandthedecisionsthattheinvestigationisintendedto
5.2.2.4 Regulatory registration data;
support. This guide does not provide methods to establish
5.2.2.5 Warranty registration data; and
specific user investigation requirements nor does it establish
5.2.2.6 Photos and videos of the original installation.
minimum levels of documentation.
5.2.3 Operating and Maintenance Manuals—Some equip-
4.6 This guide is not intended to require the user to conduct
mentmanufacturersmakecopiesofoperationandmaintenance
a failure investigation.
manuals available in printed or electronic form. The user can
4.7 This guide is focused on the identification,
check the manufacturers’ web sites for ordering or download-
documentation, and preservation of underground storage tank ing manuals.
system equipment problems. It does not provide guidance on
5.2.4 Repair records;
establishing root causes of malfunction or failure. The identi-
5.2.5 Inventory control records;
fication of root causes of malfunction or failure may require
5.2.6 Release detection records;
further expert analysis of the data and equipment collected
5.2.7 Equipment alarm histories;
during the failure investigation.
5.2.8 Tightness testing records; and
4.8 This guide does not address all the safety measures that
5.2.9 Prior monitoring well, site assessment and remedia-
must be taken when removing and disassembling underground
tion records.
storage tank systems. Because most underground storage tank
5.3 Pinpointing The Source of a Release and Malfunction-
systems have contained flammable or combustible liquids
ing Equipment in an Operating or Undisturbed Tank System:
special precautions should be taken to prevent fire, explosions
5.3.1 Visual—Careful observation of the equipment may
and exposure to toxic vapors.API standard STD 2015 and RP
reveal misalignment of equipment and malfunctioning compo-
2016 address some of the safety considerations as do many of
nents. While not always the case, generally underground
the procedures available from fire departments.
storage tank equipment is installed in alignment and should
remain in alignment throughout the life of the system. Poor
5. Elements of Failure Investigation
alignment of the installed equipment may indicate shifting,
5.1 The guide will acquaint users with methods and tools
settling,creep,expansionorfailureofcomponents.Installation
that may be used in investigations of equipment problems
photos when compared to the current conditions may help
associated with petroleum underground storage tanks and
determine if the condition of the underground storage tank
releases. The user may include a subset of the methods
system has deteriorated. Visual indicators of potential prob-
described in this guide in their investigation. The user may
lems in the underground storage tank system include, but are
co
...

NOTICE: This standard has either been superseded and replaced by a new version or withdrawn.
Contact ASTM International (www.astm.org) for the latest information
Designation: E2733 − 10 (Reapproved 2015)
Standard Guide for
Investigation of Equipment Problems and Releases for
Petroleum Underground Storage Tank Systems
This standard is issued under the fixed designation E2733; 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.
INTRODUCTION
This guide provides a framework for the development of procedures and directions for the
investigation of equipment problems associated with petroleum underground storage tank (UST)
systems and releases. It gives the user practical suggestions of how to investigate equipment and
installation problems, document findings, and in some cases prepare samples of failed equipment for
laboratory analysis. Use of this guide may result in the identification of equipment and installation
problems that can be corrected in future tank system designs and equipment maintenance programs to
prevent releases to the environment.
1. Scope protocols, they may find that the investigations can be stream-
lined for certain types of facilities.
1.1 Overview—This guide is an organized collection of
information and series of options for industry, regulators,
1.2 Limitations of This Guide:
consultants and the public, intended to assist with the devel-
1.2.1 Given the variability of the different investigators that
opment of investigation protocols for underground storage tank
may wish to use this guide and the different types of facilities
facilities in the United States. While the guide does not
and failures that will be investigated, it is not possible to
recommend a specific course of action, it establishes an
address all the relevant standards that might apply to a
investigation framework, and it provides a series of techniques
particular investigation. This guide uses generalized language
that may be employed to: identify equipment problems; in
and examples to guide the user. If it is not clear to the user how
some cases prepare samples of failed equipment for laboratory
to apply standards to their specific circumstances, it is recom-
analysis; and document the investigation. The guide includes
mended that users seek assistance from qualified professionals.
information on methods of investigation, documentation, tak-
1.2.2 This guide does not address safety issues associated
ing samples of problem equipment; preservation of equipment
with the investigation, taking samples and storing equipment.
samples; chain of custody; storage; shipping; working with
users are cautioned to exercise proper care in handling equip-
equipment manufacturers; and notification of regulators and
ment that was in contact with flammable and combustible
listing laboratories. The goal in using the guide is to identify
liquids and vapors. Some of the activities described in this
the appropriate level of investigation and to gather and
guide may be subject to OSHA (Occupational Safety and
preserve information in an organized manner, which could be
Health Administration) regulations or may only be conducted
used in the future to improve system design or performance.
by individuals with appropriate HAZWOPER (Hazardous
While this guide may act as a starting point for users with
Waste Operations and Emergency Response) training certifi-
limited experience in failure investigation, the user is encour-
cations recognized by federal and state regulatory authorities,
aged to consult with failure analysis experts for specific
such as HAZWOPER training.
investigation procedures that may be needed for certain equip-
ment and the investigation should be conducted by a qualified
1.2.3 This guide does not address laboratory investigations
professional. As users develop their specific investigation
of material properties and detailed failure analysis.
1.2.4 This guide does not cover underground storage tank
systems storing liquefied petroleum gas (LPG).
This guide is under the jurisdiction of ASTM Committee E50 on Environmental
Assessment, Risk Management and Corrective Action and is the direct responsibil-
1.2.5 This guide does not replace state-required closure
ity of Subcommittee E50.01 on Storage Tanks.
assessments and investigations. Requirements vary from state
Current edition approved April 1, 2015. Published May 2015. DOI: 10.1520/
E2733–10R15. to state and often include specific sampling requirements.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2733 − 10 (2015)
1.3 The values stated in inch-pound units are to be regarded 4. Significance and Use
as standard. No other units of measurement are included in this
4.1 This guide may be used in the investigation of under-
standard.
ground storage tank systems for equipment problems in a wide
variety of applications. Use of this guide is voluntary. It is
2. Referenced Documents
intended to assist users who want to investigate equipment
2.1 ASTM Standards:
failures and malfunctions.
E1188 Practice for Collection and Preservation of Informa-
4.2 The following groups of users may find the guide
tion and Physical Items by a Technical Investigator
particularly helpful:
F1127 Guide for Containment of Hazardous Material Spills
4.2.1 Storage tank system designers;
by Emergency Response Personnel
4.2.2 Storage tank installers;
2.2 Other Standards:
4.2.3 Storage tank maintenance contractors;
STD 2015 Requirements for Safe Entry and Cleaning of
4.2.4 Storage tank removal contractors;
Petroleum Storage Tanks, 6th Edition—August 2001
4.2.5 Storage tank inspectors;
RP 2016 Guidelines and Procedures for Entering and Clean-
4.2.6 Federal, state or local regulators, including depart-
ing Petroleum Storage Tanks, 1st Edition—August 2001
ments of health, departments of environmental protection, and
PEI/RP 100 Recommended Practices for Installation of Un-
fire departments;
derground Liquid Petroleum Storage Systems, Petroleum
4.2.7 Storage tank release detection installers;
Equipment Institute (PEI)
4.2.8 Storage tank testers;
NFPA 30 Flammable and Combustible Liquids Code
4.2.9 Petroleum release remediation consultants;
2.3 Federal Regulations:
4.2.10 Storage tank equipment manufacturers;
49 CFR 172 Hazardous Materials Table, Special Provisions,
4.2.11 Insurance adjusters;
Hazardous Materials Communications, Emergency Re-
4.2.12 Storage tank owners and operators;
sponse Information, and Training Requirements
4.2.12.1 Retail fuel service station owners and operators;
29 CFR 1910.146 Occupational Safety and Health
4.2.12.2 Small businesses or enterprises;
Standards, Subpart J, General Environmental Controls,
4.2.12.3 Service industries;
Permit-required Confined Spaces
4.2.12.4 Waste managers, including liquid and solid waste
haulers, treatment, recycling, disposal and transfer;
3. Terminology
4.2.12.5 Non-regulatory government agencies, such as the
3.1 Definitions:
military;
3.1.1 equipment problems or problem equipment—any
4.2.12.6 Specific industrial sectors such as dry cleaners,
failure, malfunction, or other issue that has resulted in abnor-
printers, photo processors, laboratories; and
mal equipment condition or operation or that has resulted in a
4.2.13 Consultants, auditors, inspectors, and compliance
release or suspected release.
assistance personnel.
3.1.2 release prevention—activities that reduce the risk of
4.3 This guide is intended to assist in the development of
human and environmental exposure to petroleum or hazardous
protocols for the investigation of a malfunction or failure of
substances. In the United States, underground storage tank and
storage tank systems and the implementation of said protocols.
toxic use reduction regulations are examples of such require-
This guide outlines steps that may be necessary and include,
ments.
but are not limited to initial evaluation of the UST system to
3.1.3 underground storage tank—a tank and any under-
determine the malfunction(s); preparation of samples of failed
ground piping connected to the tank that has at least 10 % of its
equipment for laboratory analysis; and document the investi-
combined volume underground.
gation. The guide provides a series of investigation options on
which the user may design failure investigation protocols. The
3.1.4 waste—discarded solid or liquid materials that may be
guide describes common investigation techniques in the order
hazardous to public health or the environment. Solid and
in which they might be employed in an investigation.
hazardous waste require controls on handling, transport, stor-
age treatment, and disposal.
4.4 A user may elect to utilize this guide for a number of
reasons, which include, but are not limited to:
4.4.1 To differentiate new releases from new discovery of
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
old releases;
contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
4.4.2 To establish malfunction and failure rates of various
Standards volume information, refer to the standard’s Document Summary page on
the ASTM website. storage tank equipment components;
Available from American Petroleum Institute (API), 1220 L. St., NW,
4.4.3 To determine expected life spans of various storage
Washington, DC 20005-4070, http://www.api.org.
tank equipment components;
Available from Petroleum Equipment Institute (PEI), P. O. Box 2380, Tulsa,
4.4.4 To identify opportunities for improving the perfor-
OK 74101-2380, http://www.pei.org.
Available from National Fire Protection Association (NFPA), 1 Batterymarch
mance and reliability of storage tank equipment;
Park, Quincy, MA 02169-7471, http://www.nfpa.org.
4.4.5 To focus inspection and maintenance efforts on those
Available from U.S. Government Printing Office Superintendent of Documents,
portions of the tank system that are most prone to malfunction
732 N. Capitol St., NW, Mail Stop: SDE, Washington, DC 20401, http://
www.access.gpo.gov. and failure;
E2733 − 10 (2015)
4.4.6 To identify those components of the storage tank 5.2 General Records—Gathering and reviewing records
system that require more frequent maintenance; prior to the physical investigation may help focus the investi-
gation and make the investigation run smoothly. Reviewing
4.4.7 To reduce remediation and equipment replacement
records from the following categories may help inform the user
costs;
what types of equipment to expect, where the equipment can be
4.4.8 To prevent petroleum releases;
found, the repair and maintenance history and prior releases.
4.4.9 To identify those conditions that may cause or con-
These records may be in the possession of the owner(s) of the
tribute to the deterioration or cause the malfunction and failure
petroleum underground storage tank system; a third party
of various components of the UST system; and
consultant or maintenance contractor; or one or more regula-
4.4.10 To comply with environmental regulations that
tory entities. The user may find that it is beneficial to organize
require the investigation of release detection alarms and the
the records and bring them to the field investigation for
source of releases.
reference.
4.5 This guide may be used to establish a framework, which
5.2.1 Equipment purchase records.
pulls together the common approaches to investigation. The
5.2.2 Installation records:
framework will allow the user to establish an investigation
5.2.2.1 “Record” or “as-built” drawings andor site plans;
protocol to meet their specific requirements. Specific user
5.2.2.2 Installation check lists;
requirements will vary depending upon the purposes of the data
5.2.2.3 Pre-operation leak checks;
collection and the decisions that the investigation is intended to
5.2.2.4 Regulatory registration data;
support. This guide does not provide methods to establish
5.2.2.5 Warranty registration data; and
specific user investigation requirements nor does it establish
5.2.2.6 Photos and videos of the original installation.
minimum levels of documentation.
5.2.3 Operating and Maintenance Manuals—Some equip-
4.6 This guide is not intended to require the user to conduct
ment manufacturers make copies of operation and maintenance
a failure investigation.
manuals available in printed or electronic form. The user can
4.7 This guide is focused on the identification, check the manufacturers’ web sites for ordering or download-
documentation, and preservation of underground storage tank
ing manuals.
system equipment problems. It does not provide guidance on
5.2.4 Repair records;
establishing root causes of malfunction or failure. The identi-
5.2.5 Inventory control records;
fication of root causes of malfunction or failure may require
5.2.6 Release detection records;
further expert analysis of the data and equipment collected
5.2.7 Equipment alarm histories;
during the failure investigation.
5.2.8 Tightness testing records; and
4.8 This guide does not address all the safety measures that
5.2.9 Prior monitoring well, site assessment and remedia-
must be taken when removing and disassembling underground
tion records.
storage tank systems. Because most underground storage tank
5.3 Pinpointing The Source of a Release and Malfunction-
systems have contained flammable or combustible liquids
ing Equipment in an Operating or Undisturbed Tank System:
special precautions should be taken to prevent fire, explosions
5.3.1 Visual—Careful observation of the equipment may
and exposure to toxic vapors. API standard STD 2015 and RP
reveal misalignment of equipment and malfunctioning compo-
2016 address some of the safety considerations as do many of
nents. While not always the case, generally underground
the procedures available from fire departments.
storage tank equipment is installed in alignment and should
remain in alignment throughout the life of the system. Poor
5. Elements of Failure Investigation
alignment of the installed equipment may indicate shifting,
5.1 The guide will acquaint users with methods and tools
settling, creep, expansion or failure of components. Installation
that may be used in investigations of equipment problems
photos when compared to the current conditions may help
associated with petroleum underground storage tanks and
determine if the condition of the underground storage tank
releases. The user may include a subset of the methods
system has deteriorated. Visual indicators of potential prob-
described in this guide in their investigation. The user may
lems in the underground storage tank system include, but are
consider a variety of factors in de
...

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: E2733 − 10 E2733 − 10 (Reapproved 2015)
Standard Guide for
Investigation of Equipment Problems and Releases for
Petroleum Underground Storage Tank Systems
This standard is issued under the fixed designation E2733; 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.
INTRODUCTION
This guide provides a framework for the development of procedures and directions for the
investigation of equipment problems associated with petroleum underground storage tank (UST)
systems and releases. It gives the user practical suggestions of how to investigate equipment and
installation problems, document findings, and in some cases prepare samples of failed equipment for
laboratory analysis. Use of this guide may result in the identification of equipment and installation
problems that can be corrected in future tank system designs and equipment maintenance programs to
prevent releases to the environment.
1. Scope
1.1 Overview—This guide is an organized collection of information and series of options for industry, regulators, consultants
and the public, intended to assist with the development of investigation protocols for underground storage tank facilities in the
United States. While the guide does not recommend a specific course of action, it establishes an investigation framework, and it
provides a series of techniques that may be employed to: identify equipment problems; in some cases prepare samples of failed
equipment for laboratory analysis; and document the investigation. The guide includes information on methods of investigation,
documentation, taking samples of problem equipment; preservation of equipment samples; chain of custody; storage; shipping;
working with equipment manufacturers; and notification of regulators and listing laboratories. The goal in using the guide is to
identify the appropriate level of investigation and to gather and preserve information in an organized manner, which could be used
in the future to improve system design or performance. While this guide may act as a starting point for users with limited
experience in failure investigation, the user is encouraged to consult with failure analysis experts for specific investigation
procedures that may be needed for certain equipment and the investigation should be conducted by a qualified professional. As
users develop their specific investigation protocols, they may find that the investigations can be streamlined for certain types of
facilities.
1.2 Limitations of This Guide:
1.2.1 Given the variability of the different investigators that may wish to use this guide and the different types of facilities and
failures that will be investigated, it is not possible to address all the relevant standards that might apply to a particular investigation.
This guide uses generalized language and examples to guide the user. If it is not clear to the user how to apply standards to their
specific circumstances, it is recommended that users seek assistance from qualified professionals.
1.2.2 This guide does not address safety issues associated with the investigation, taking samples and storing equipment. users
are cautioned to exercise proper care in handling equipment that was in contact with flammable and combustible liquids and
vapors. Some of the activities described in this guide may be subject to OSHA (Occupational Safety and Health Administration)
regulations or may only be conducted by individuals with appropriate HAZWOPER (Hazardous Waste Operations and Emergency
Response) training certifications recognized by federal and state regulatory authorities, such as HAZWOPER training.
1.2.3 This guide does not address laboratory investigations of material properties and detailed failure analysis.
1.2.4 This guide does not cover underground storage tank systems storing liquefied petroleum gas (LPG).
1.2.5 This guide does not replace state-required closure assessments and investigations. Requirements vary from state to state
and often include specific sampling requirements.
This guide is under the jurisdiction of ASTM Committee E50 on Environmental Assessment, Risk Management and Corrective Action and is the direct responsibility
of Subcommittee E50.04 on Corrective Action.
Current edition approved Aug. 1, 2010April 1, 2015. Published September 2010May 2015. DOI: 10.1520/E2733–10.10.1520/E2733–10R15.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
E2733 − 10 (2015)
1.3 The values stated in inch-pound units are to be regarded as standard. No other units of measurement are included in this
standard.
2. Referenced Documents
2.1 ASTM Standards:
E1188 Practice for Collection and Preservation of Information and Physical Items by a Technical Investigator
F1127 Guide for Containment of Hazardous Material Spills by Emergency Response Personnel
2.2 Other Standards:
STD 2015 Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks, 6th Edition—August 2001
RP 2016 Guidelines and Procedures for Entering and Cleaning Petroleum Storage Tanks, 1st Edition—August 2001
PEI/RP 100 Recommended Practices for Installation of Underground Liquid Petroleum Storage Systems, Petroleum Equipment
Institute (PEI)
NFPA 30 Flammable and Combustible Liquids Code
2.3 Federal Regulations:
49 CFR 172 Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response
Information, and Training Requirements
29 CFR 1910.146 Occupational Safety and Health Standards, Subpart J, General Environmental Controls, Permit-required
Confined Spaces
3. Terminology
3.1 Definitions:
3.1.1 equipment problems or problem equipment—any failure, malfunction, or other issue that has resulted in abnormal
equipment condition or operation or that has resulted in a release or suspected release.
3.1.2 release prevention—activities that reduce the risk of human and environmental exposure to petroleum or hazardous
substances. In the United States, underground storage tank and toxic use reduction regulations are examples of such requirements.
3.1.3 underground storage tank—a tank and any underground piping connected to the tank that has at least 10 % of its combined
volume underground.
3.1.4 waste—discarded solid or liquid materials that may be hazardous to public health or the environment. Solid and hazardous
waste require controls on handling, transport, storage treatment, and disposal.
4. Significance and Use
4.1 This guide may be used in the investigation of underground storage tank systems for equipment problems in a wide variety
of applications. Use of this guide is voluntary. It is intended to assist users who want to investigate equipment failures and
malfunctions.
4.2 The following groups of users may find the guide particularly helpful:
4.2.1 Storage tank system designers;
4.2.2 Storage tank installers;
4.2.3 Storage tank maintenance contractors;
4.2.4 Storage tank removal contractors;
4.2.5 Storage tank inspectors;
4.2.6 Federal, state or local regulators, including departments of health, departments of environmental protection, and fire
departments;
4.2.7 Storage tank release detection installers;
4.2.8 Storage tank testers;
4.2.9 Petroleum release remediation consultants;
4.2.10 Storage tank equipment manufacturers;
4.2.11 Insurance adjusters;
4.2.12 Storage tank owners and operators;
4.2.12.1 Retail fuel service station owners and operators;
4.2.12.2 Small businesses or enterprises;
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
Available from American Petroleum Institute (API), 1220 L. St., NW, Washington, DC 20005-4070, http://www.api.org.
Available from Petroleum Equipment Institute (PEI), P. O. Box 2380, Tulsa, OK 74101-2380, http://www.pei.org.
Available from National Fire Protection Association (NFPA), 1 Batterymarch Park, Quincy, MA 02169-7471, http://www.nfpa.org.
Available from U.S. Government Printing Office Superintendent of Documents, 732 N. Capitol St., NW, Mail Stop: SDE, Washington, DC 20401, http://
www.access.gpo.gov.
E2733 − 10 (2015)
4.2.12.3 Service industries;
4.2.12.4 Waste managers, including liquid and solid waste haulers, treatment, recycling, disposal and transfer;
4.2.12.5 Non-regulatory government agencies, such as the military;
4.2.12.6 Specific industrial sectors such as dry cleaners, printers, photo processors, laboratories; and
4.2.13 Consultants, auditors, inspectors, and compliance assistance personnel.
4.3 This guide is intended to assist in the development of protocols for the investigation of a malfunction or failure of storage
tank systems and the implementation of said protocols. This guide outlines steps that may be necessary and include, but are not
limited to initial evaluation of the UST system to determine the malfunction(s); preparation of samples of failed equipment for
laboratory analysis; and document the investigation. The guide provides a series of investigation options on which the user may
design failure investigation protocols. The guide describes common investigation techniques in the order in which they might be
employed in an investigation.
4.4 A user may elect to utilize this guide for a number of reasons, which include, but are not limited to:
4.4.1 To differentiate new releases from new discovery of old releases;
4.4.2 To establish malfunction and failure rates of various storage tank equipment components;
4.4.3 To determine expected life spans of various storage tank equipment components;
4.4.4 To identify opportunities for improving the performance and reliability of storage tank equipment;
4.4.5 To focus inspection and maintenance efforts on those portions of the tank system that are most prone to malfunction and
failure;
4.4.6 To identify those components of the storage tank system that require more frequent maintenance;
4.4.7 To reduce remediation and equipment replacement costs;
4.4.8 To prevent petroleum releases;
4.4.9 To identify those conditions that may cause or contribute to the deterioration or cause the malfunction and failure of
various components of the UST system; and
4.4.10 To comply with environmental regulations that require the investigation of release detection alarms and the source of
releases.
4.5 This guide may be used to establish a framework, which pulls together the common approaches to investigation. The
framework will allow the user to establish an investigation protocol to meet their specific requirements. Specific user requirements
will vary depending upon the purposes of the data collection and the decisions that the investigation is intended to support. This
guide does not provide methods to establish specific user investigation requirements nor does it establish minimum levels of
documentation.
4.6 This guide is not intended to require the user to conduct a failure investigation.
4.7 This guide is focused on the identification, documentation, and preservation of underground storage tank system equipment
problems. It does not provide guidance on establishing root causes of malfunction or failure. The identification of root causes of
malfunction or failure may require further expert analysis of the data and equipment collected during the failure investigation.
4.8 This guide does not address all the safety measures that must be taken when removing and disassembling underground
storage tank systems. Because most underground storage tank systems have contained flammable or combustible liquids special
precautions should be taken to prevent fire, explosions and exposure to toxic vapors. API standard STD 2015 and RP 2016 address
some of the safety considerations as do many of the procedures available from fire departments.
5. Elements of Failure Investigation
5.1 The guide will acquaint users with methods and tools that may be used in investigations of equipment problems associated
with petroleum underground storage tanks and releases. The user may include a subset of the methods described in this guide in
their investigation. The user may consider a variety of factors in determining which combination of the methods to employ. For
example, the manner of discovering a release may influence the methods employed. If there is an indication of a release from
release detection or off site impacts, the user may select failure investigation methods that rely on records reviews and
non-destructive tests. If the release is discovered during tank removal, some equipment tests may not be possible, and the user may
choose visual examination techniques. If there are no indications of a release, the user may choose to employ visual examination
techniques to check on the site assessment information that indicated that no release occurred.
5.2 General Records—Gathering and reviewing records prior to the physical investigation may help focus the investigation and
make the investigation run smoothly. Reviewing records from the following categories may help inform the user what types of
equipment to expect, where the equipment can be found, the repair and maintenance history and prior releases. These records may
be in the possession of the owner(s) of the petroleum underground storage tank system; a third party consultant or maintenance
contractor; or one or more regulatory entities. The user may find that it is beneficial to organize the records and bring them to the
field investigation for reference.
5.2.1 Equipment purchase records.
5.2.2 Installation records:
E2733 − 10 (2015)
5.2.2.1 “Record” or “as-built” drawings andor site plans;
5.2.2.2 Installation check lists;
5.2.2.3 Pre-operation leak checks;
5.2.2.4 Regulatory registration data;
5.2.2.5 Warranty registration data; and
5.2.2.6 Photos and videos of the original installation.
5.2.3 Operating and Maintenance Manuals—Some equipment manufacturers make copies of operation and maintenance
manuals available in printed or electronic form. The user can check the manufacturers’ web sites for ordering or downloading
manuals.
5.2.4 Rep
...