Corrosion in Underground Storage Tanks (USTs) Storing Diesel. Summary, Findings, and Impacts of EPA s July 2016 Research

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Corrosion in Underground Storage Tanks (USTs) Storing Diesel Summary, Findings, and Impacts of EPA s July 2016 Research

Why Research Corrosion in USTs Storing Diesel? Reports began around 2007 Internal metal components (often STP shaft) Severe and rapid onset Unidentified cause Extent not fully understood before this research, or after Appearance different and impacts more severe than corrosion in sump spaces of USTs storing gasoline/ethanol blends

Key points from the research Research showed corrosion in most USTs studied. Owners may not be aware it is affecting their UST system Corrosion may impact equipment functionality in a couple of ways, and could pose a risk of release of fuel to the environment Metal components in steel and fiberglass tanks

Investigation of Corrosion-Influencing Factors - Released July 2016 Research Goals: To better understand the extent of the problem and identify potential risks Identify any correlations or predictive factors among UST systems with severe or minimal corrosion Timeline of Research and Review Process: Field and lab work completed spring 2015 Stakeholder review of initial draft summer 2015 Peer-review winter 2015-16

# of USTs Investigation Locations and Tank Population 20 16 12 8 4 42 USTs by Capacity and Material 0 5,000 6,000 7,000 8,000 10,000 12,000 15,000 20,000 Tank Capacity (gallons) Steel Fiberglass 5

Many locations 42 sites 24 fiberglass, 16 steel, 2 steel coated 8 of 10 have steel and fiberglass in cluster Diverse UST Sample Population 8 different owners Government, retail, fleet Single and multiple site Large range of fuel throughputs and suppliers Diverse USTs 1 29 years in service 5,000 to 20,000 gallons in capacity Different product storage histories Various approaches to maintenance

Data Collection on UST Conditions Collect samples: Vapor Fuel Water bottom Inspect with internal tank video Collect information on maintenance, throughput, fuel supply, biocide use, etc.

Fuel Analysis Methods Method Identifier Determination of Water in Petroleum Products, Lubricating Oils, and Additiv es by Coulometric Karl Fischer Titration (Procedure B) ASTM D6304 8 Determination of Density, Relative Density, and API Gravity of Liquids by Digital Density Meter Acid Number of Petroleum Products by Potentiometric Titration Determining Corrosiv e Properties of Cargoes in Petroleum Product Pipelines Particulate Contamination in Middle Distillate Fuels by Laboratory Filtration Determination of Biodiesel (FAME) Content in Diesel Fuel Oil Using Mid Infrared Spectroscopy (FITR-ATR-PLS Method) ASTM D4052 10 Fuel ASTM D664 11 NACE TM-172 12 ASTM D6217 13 ASTM D7371 14 Water Content Density Total Acid Number Corrosion Rating Particulates Biodiesel Content Flash Point by Pensky-Martens Closed Cup Tester ASTM D93 15 Flashpoint Determination of Free and Total Glycerin in Biodiesel Blends by Anion Exchange ASTM D7591 16 Free and Total Glycerin Chromatography GC-MS Full Scan Lab In-House Method Unknowns of Interest Determination of Total Sulfur in Light Hydrocarbons, Spark Ignition Engine Fuel, Diesel Engine Fuel, and Engine Oil by Ultraviolet ASTM D5453 17 Sulfur Content Fluorescence Electrical Conductivity of Aviation and Distillate Fuels ASTM D2624 18 Conductivity Determination of Short Chain Fatty Acids by Gas Chromatography-Mass Spectrometry (GC-MS) FUEL Lab In-House Method Acetate, Formate, Propionate, Lactate, Glycerate Sample Analyses Water Water Bottom Analysis Methods Method Identifier Determination of Ion Chromatography (IC) for short chain fatty acids Modified EPA 300 Acetic, Formic, Propionic, Lactic Acids IC Test for Free Glycerin Lab In-House Method Glycerin Determination of Dissolved Alkali and Alkaline Earth Cations and Ammonium in Water and Wastewater by Ion Chromatography ASTM D6919 19 Cations (Sodium, Calcium, Magnesium, Potassium, Ammonium) and Anions (Chloride, Sulfate, Nitrate and Fluoride) ph (Electric) EPA 150.1 20 ph Conductance (Specific Conductance, umhos at 25 C) EPA 120.1 21 Conductivity Nonhalogenated Organics Using GC/FID SW846 8015B 22 Ethanol and Methanol VAPOR Vapor Analysis Methods Method Identifier Determination of Ullage % Relative Humidity Hygrometer used per manufacturer instructions % relative humidity Carboxylic Acids in Ambient Air Using GC-MS Determination of Lactic Acid in Ambient Air ALS Method 102 Modified NIOSH 7903 Acetic, Formic, Propionic, and Butyric Acids Lactic Acid

Study Findings Corrosion more prevalent than anticipated 83% had moderate or severe corrosion Many owners were not aware they had corrosion sample was biased, but less than 25% initially believed they had corrosion No statistically significant predictive factors

Corrosion Prevalence in 42 USTs 20 16 12 8 4 0 42 USTs by Corrosion Category and Material 9 11 4 3 8 7 Minimal Moderate Severe Steel Fiberglass Note: EPA asked for sites with corrosion, so sample is biased. But less than 25 percent of the sample population was aware of corrosion before investigation. Red = steel Brown = Fiberglass (Total Population = 24 fiberglass, 18 steel)

Potential Risks to the Environment Exposed Metals in the Vapor Space Release prevention equipment could corrode and fail to function Corrosion on flapper valves could restrict movement and allow an overfill Product level floats get stuck on corroded shafts and fail to signal a rising product level, fuel release, or water infiltration Ball float valves ball or cage may corrode Line leak detectors could be failing performance testing at higher rates Shear valves may jam

Potential Risks to the Environment (continued) Bottoms of Tanks Metal components could potentially corrode through and possibly release fuel to environment Diesel prone to collect water and sludge in bottom of tanks Study results prompted conversations heard handful of anecdotes of bottom repairs of primary walls of double-wall steel tank bottoms after leak to interstitial - sometimes a lack of leak detection alarms but fluid in interstitial space prompted further inspection

Takeaways Corrosion of metal components in UST systems storing diesel appears to be common. Many owners are likely not aware of corrosion in their diesel UST systems. The corrosion is geographically widespread, affects UST systems with steel tanks and with fiberglass tanks, and poses a risk to most internal metal components. Ethanol was present in 90 percent of 42 samples, suggesting that cross-contamination of diesel fuel with ethanol is likely the norm, not the exception.

Other Key Takeaways Continued The quality of diesel fuel stored in USTs was mixed. Particulates and water content in the fuel were closest to being statistically significant predictive factors for metal corrosion, but causation cannot be discerned. MIC could be involved as hypothesized by previous research. EPA recommends owners visually inspect USTs storing diesel as part of routine monitoring.

From ASTM D975: X6 MICROBIAL CONTAMINATION X6.1 Uncontrolled microbial contamination in fuel systems can cause or contribute to a variety of problems, including increased corrosivity and decreased stability, filterability, and caloric value. Microbial processes in fuel systems can also cause or contribute to system damage. X6.2 Because the microbes contributing to the problems listed in X6.1 are not necessarily present in the fuel itself, no microbial quality criterion for fuels is recommended. However, it is important that personnel responsible for fuel quality understand how uncontrolled microbial contamination can affect fuel quality. X6.3 Guide D6469 provides personnel with limited microbiological background an understanding of the symptoms, occurrences, and consequences of microbial contamination. Guide D6469 also suggests means for detecting and controlling microbial contamination in fuels and fuel systems. Good housekeeping, especially keeping fuel dry, is critical.

Takeaways Microbiologically influenced corrosion (MIC) likely largely responsible for the corrosion. Eliminating water is recognized as a key factor in preventing this corrosion. Unsure about Emergency Generator Tanks and Aboveground Storage Tanks probably similar corrosion

Resources Coordinating Research Council (CRC): Report 672 - Preventive Maintenance Guide for Diesel Storage and Dispensing Systems (http://www.crcao.org/reports/recentstudies2016/crc%20672/crc %20672.pdf) Report 667 - Diesel Fuel Storage and Handling Guide (http://www.crcao.org/reports/recentstudies2014/crc%20667/crc %20667.pdf) Clean Diesel Fuel Alliance: Guidance for Underground Storage Tank Management at ULSD Dispensing Facilities (http://www.cleandiesel.org/pdf/guidanceforundergroundstoragetankmanagement_fin AL.pdf) Steel Tank Institute - R111 Storage Tank Maintenance Standard (http://www.steeltank.com/portals/0/shop%20fab/r111%20%20with% 20updated%20cover.pdf) ASTM D6469, Standard Guide for Microbial Contamination in Fuels and Fuel Systems (http://www.astm.org/standards/d6469.htm) (Note: this document is publicly available but must be purchased) 17

Additional Information EPA Office of Underground Storage Tanks Website https://www.epa.gov/ust EPA Office of Underground Storage Tanks Emerging Fuels Contact Ryan Haerer at haerer.ryan@epa.gov or 202-564-0762 18