No. The Bravo Conversion Frame (DCF) was developed to contain and control falling fuel spilled from a filter replacement, or small incremental leaks within the hydraulic cabinet area of a dispenser only. This area that we targeted when we started this Secondary Containment industry does not include the often spacious “vapor panels” that are common today.
It is true that in some cases the fuel line for the exterior hose has a threaded connection at the valance-level and runs partially or mostly within the vapor panel area but it is typically a solid, continuous line running to the connection point within the hydraulic cabinet area of the dispenser. This area or the connection(s) that happen there have never before been scrutinized or required to be secondarily contained. What is more, State Waterboard staff have relayed their opinion that the Bravo DCF accomplishes its function of funneling any fuel leaks from the hydraulic cabinet into the UDC and meets the intent of the law. So it is Bravo’s opinion that…
A) The likelihood of the fuel lines leaking from anywhere except a threaded connection is low and there should not be any such points between a primary connection within the hydraulic cabinet and the point that it transitions to the hose on the exterior.
B) Any leaks that might occur from the threads of these lines are going to follow gravity down the path of least resistance – all while evaporating – and if any liquid actually does run down the line into the hydraulic cabinet area it is collected by our Dispenser Conversion Frame (DCF – CONV-B2000). Leaks are not likely to fall from the pipe line within the vapor panel area.
C) By providing a capture mechanism in the vapor panel that directs potentially falling fuel into the UDC we would be bypassing the established and proven function of the water-splash lip by creating a point where water can be captured as well, increasing the risk of water accumulation and false alarms. We seek to first maintain our decades-old reputation of maintaining regulatory compliance in the pursuit of environmental and human safety. But this includes helping our customers avoid unnecessary and potentially costly false alarms.
D) There should be no requirement for Retroactive modifications. Simply put, Bravo does not condone or seek to bring about additional mandatory costs to our customers unless the environment or human health is at risk. In this case we do not consider the vapor panel area of dispensers to pose any threat to either.
FOR CALIFORNIA: State law prohibits anything that increases false alarms due to water intrusion and such alarms can result in full station shut-down which is directly associated with a loss of revenue.
BET YOU DIDN’T KNOW: The Bravo Dispenser Conversion Frame was first launched in 1991, some 16 years before the State of CA made a UDSCCS (Under Dispenser Secondary Containment or Control System) mandatory for dissimilar dispenser upgrades/change outs. We hope you didn’t think that our product was simply built to comply with the 2007 mandate.
Feel free to contact the SWRCB – Click here for UST division contact info