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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
8/20/2014
ASTSWMO
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”
8/20/2014
ASTSWMO
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
8/20/2014
ASTSWMO
UST Compliance and Prevention Workshop 7
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)
8/20/2014
ASTSWMO
UST Compliance and Prevention Workshop 8
Alternative Fuels
Biodiesel
Bio in ULSD for lubricity
Bio in Off road diesel
Bio in #2 Heating Oil
B5-20, B21-B99ish, B100ish
8/20/2014
ASTSWMO
UST Compliance and Prevention Workshop 9
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?
8/20/2014
ASTSWMO
UST Compliance and Prevention Workshop 10
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?
8/20/2014
ASTSWMO
UST Compliance and Prevention Workshop 14
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
8/20/2014
ASTSWMO
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
8/20/2014
ASTSWMO
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
ASTSWMO
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
(603) 271-6058
9/23/2014
EPA Region 1 and 2
UST Inspector Training 19