8/20/14

ASTSWMO

UST Compliance and Prevention Workshop1

Tank Lining Issues

Michael Juranty, P.E.

NHDES

8/20/2014

ASTSWMO

UST Compliance and Prevention Workshop 2

Introduction

Lining vs. Field Erected Tank

Lining Considerations

Regulatory Requirements

Tank Access for Lining

Compatibility of Lining

Field Erected Tanks

• Tank Standards

• Permanent Closure of Host Tank

Lining vs. Field Erected Tank

Lining = Continued Service of host tank

Field Erected Tank REPLACES host tank

which is Permanently Closed in place

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UST Compliance and Prevention Workshop 3

Tank Lining Considerations

Why is it being lined?

Repair requirements?

Is there existing tank access?

40 CFR 280.33, “Owners and operators

must ensure that repairs will prevent

releases due to structural failure or

corrosion”

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UST Compliance and Prevention Workshop 4

Manway Installation

API Standard 1631, Interior Lining and

Periodic Inspection of Underground

Storage Tanks

UL 58

UL 1746

Manufacturer’s requirement (fiberglass)

NLPA Standard 631, Interior Inspection,

Repair, and Lining of Steel and Fiberglass

Storage Tanks

9/23/2014

EPA Region 1 and 2

UST Inspector Training 5

8/20/2014

ASTSWMO

UST Compliance and Prevention Workshop 6

Is Lining Compatible?

40 CFR 280.32 “Owners and operators

must use an UST system made of or lined

with materials that are compatible with the

substance stored in the UST system”

Owens Corning Letters:

Docket ID EPA-HQ-UST-2010-0651

April 14, 1995

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Alternative Fuels

Materials Not Compatible w/ Ethanol:

Polymers• Polyurethane

• Alcohol-based pipe dope (recently applied)

Materials possibly unsuitable are fiberglass-reinforced polyester and epoxy resins. Some fiberglass –reinforced polyester and epoxy resins have been reported to be softened.

Note: Source of information – ADM’s Fuel Ethanol Tech. Man. (2003)

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Alternative Fuels

Biodiesel

Bio in ULSD for lubricity

Bio in Off road diesel

Bio in #2 Heating Oil

B5-20, B21-B99ish, B100ish

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Alternative Fuels

Ethanol and Biodiesel act as solvents

Cleans sludge from tank bottoms

Removes “plugs” from leaks

What does it do to tanks and

linings?

ULSD Tank Corrosion?

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Alternative Fuels

Clean Dirty

Particulate

Matter

Slight

Particulate

Matter

Solid Contaminant Standards

Field Erected USTs

Replaces the Host tank which is closed in

place

Typically cost effective if replacing one

tank within a tank farm

Typically used if host tank experienced an

outer wall failure

Upgrade of single wall to double wall tank?

8/20/2014

ASTSWMO

UST Compliance and Prevention Workshop 11

8/20/2014

EPA Region 1 and 2 ASTSWMO

UST Compliance and Prevention Workshop

12

8/20/2014

ASTSWMO

UST Compliance and Prevention Workshop 13

Tank Standards

40 CFR 280.20 “Each tank must be properly

designed and constructed, in accordance with a

code of practice developed by a nationally

recognized association or independent testing

laboratory as specified below:”

(a)(1) tank is constructed of fiberglass-

reinforced plastic; or

(a)(2) tank is constructed of steel and

cathodically protected

Historic Field Erected UST

Listings ULC C58.4 “Double Containment Linings”

Xerxes Phoenix

UL 1316 retrofit listing

UL 1316 listing

TankTech Stand Alone Tank System

Containment Solution ReTank system

Is a noted listing required to meet 280.20?

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Xerxes “Phoenix LifeLiner

System” ULC C58.4 “Double Containment Fibre

Reinforced Plastic Linings for Flammable

and Combustible Liquid Storage Tanks”

NH Experience

Dover UST Facility #0115348, 31MAR10,

Fiberglass Host Tank, 10,000 gallon Diesel

Denied application in a composite tank due to

cathodic protection issues

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UST Compliance and Prevention Workshop 15

TankTech “Stand Alone System”

UL 1316 “Standard for Glass-Fiber-

Reinforced Plastic Underground Storage

Tanks…”

NH Experience:

Tank Top details (new or used?)

Manchester UST Facility #0111024, OCT13

Salem UST Facility #0111008, OCT13

Safety

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UST Compliance and Prevention Workshop 16

Host Tank Permanent Closure

Site Assessment

Closure Report

9/23/2014

EPA Region 1 and 2

UST Inspector Training 17

8/20/2014

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UST Compliance and Prevention Workshop 18

Summary

Is it a lining or a new tank?

Was the tank properly repaired?

Is the tank top tight and protected from

corrosion?

Is the lining compatible with alternative fuels?

Was the field erected tank installed per

listing?

Was the host tank properly closed?

Contact Information

Mike Juranty

NH DES

michael.juranty@des.nh.gov

(603) 271-6058

9/23/2014

EPA Region 1 and 2

UST Inspector Training 19