Tank Lining Issues. Michael Juranty, P.E. NHDES. ASTSWMO UST Compliance and Prevention Workshop 1 8/20/14

Transcription

1 Tank Lining Issues Michael Juranty, P.E. NHDES 8/20/14 UST Compliance and Prevention Workshop 1

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 UST Compliance and Prevention Workshop 2

3 Lining vs. Field Erected Tank Lining = Continued Service of host tank Field Erected Tank REPLACES host tank which is Permanently Closed in place UST Compliance and Prevention Workshop 3

4 Tank Lining Considerations Why is it being lined? Repair requirements? Is there existing tank access? 40 CFR , Owners and operators must ensure that repairs will prevent releases due to structural failure or corrosion UST Compliance and Prevention Workshop 4

5 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

6 Is Lining Compatible? 40 CFR 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 April 14, 1995 UST Compliance and Prevention Workshop 6

7 Alternative Fuels Materials Not Compatible w/ Ethanol: Polymers Polyurethane Alcohol-based pipe dope (recently applied) Materials possibly unsuitable are fiberglassreinforced 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) UST Compliance and Prevention Workshop 7

8 Alternative Fuels Biodiesel Bio in ULSD for lubricity Bio in Off road diesel Bio in #2 Heating Oil B5-20, B21-B99ish, B100ish UST Compliance and Prevention Workshop 8

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? UST Compliance and Prevention Workshop 9

10 Alternative Fuels Solid Contaminant Standards Clean Slight Particulate Matter Particulate Matter Dirty UST Compliance and Prevention Workshop 10

11 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? UST Compliance and Prevention Workshop 11

12 EPA Region 1 and 2 UST Compliance and Prevention Workshop 12

13 Tank Standards 40 CFR 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 fiberglassreinforced plastic; or (a)(2) tank is constructed of steel and cathodically protected UST Compliance and Prevention Workshop 13

14 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 ? UST Compliance and Prevention Workshop 14

15 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 # , 31MAR10, Fiberglass Host Tank, 10,000 gallon Diesel Denied application in a composite tank due to cathodic protection issues UST Compliance and Prevention Workshop 15

16 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 # , OCT13 Salem UST Facility # , OCT13 Safety UST Compliance and Prevention Workshop 16

17 Host Tank Permanent Closure Site Assessment Closure Report 9/23/2014 EPA Region 1 and 2 UST Inspector Training 17

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? UST Compliance and Prevention Workshop 18

19 Contact Information Mike Juranty NH DES (603) /23/2014 EPA Region 1 and 2 UST Inspector Training 19