Materials Performance Supplements

TANK 2018

Materials Performance is the world's most widely circulated magazine dedicated to corrosion prevention and control. MP provides information about the latest corrosion control technologies and practical applications for every industry and environment.

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23 TANK CORROSION CONTROL SUPPLEMENT TO MP MATERIALS PERFORMANCE MAY 2018 installed after December 22, 1988 must meet one of the following performance standards for corrosion protection: 3 • Tanks and piping are completely made of noncorrodible material, such as fiberglass-reinforced plastic. • Tanks and piping made of steel have a corrosion-resistant coating and cathodic protection (CP). • Tanks made of steel are clad with a thick layer of noncorrodible mate- rial (this option does not apply to piping). • Tanks and piping can be installed without additional corrosion pro- tection measures provided that a corrosion expert has determined that the site is not corrosive enough to cause the equipment to have a release due to corrosion during its operating life, and owners or oper- ators must maintain records that demonstrate compliance with this requirement. • Tank s and pipin g c onstr uction a n d c o r r o s i o n p r o t e c t i o n a r e determined by the implementing agency to be designed to prevent the release or threatened release of any stored regulated substance in a manner that is no less protective of human health and the environment than the options listed above. UST systems installed before December 22, 1988 also must be protected from corro- sion. These USTs must meet one of the cor- rosion protection standards listed previ- ously or meet one of the following upgrade options (or be properly closed): interior lining, CP, and internal lining combined with CP. Prior to adding CP, the tank integ- rity must be ensured using one of the fol- lowing methods: • The tank is internally inspected and assessed to ensure that the tank is structurally sound and free of corrosion or holes. • The tank has been installed for less than 10 years and uses monthly monitoring for releases. • The tank has been installed for less than 10 years and is assessed for corrosion holes by conducting two tightness tests—the first occurs prior to adding CP and the second occurs three to six months follow- ing the first operation of CP. • Alternative integrity assessment: the tank is assessed for corrosion holes by a method that is deter- mined by the implementing agency to prevent releases in a manner that is no less protective of human health and the environment than those listed previously. Upgrading bare metal piping is accom- plished by adding CP. Metal pipe sections and fittings that have released product due to corrosion or other damage must be re pl a c ed . P ipin g entirely m a d e of (or enclosed in) noncorrodible material does not need CP. New Rules Seek Better Leak Prevention, Detection In July 2015, to strengthen federal UST requirements so prevention and detection of p e tro l e u m re l e a s e s f ro m U STs a re improved and help ensure all USTs in the United States meet the same release pro- tection standards, the EPA made several revisions to the 1988 UST regulation and the 1988 state program approval (SPA) reg- ulation. 4 Changes to the regulations include: • Adding secondar y containm ent requirements for new and replaced tanks and piping • Adding operator training require- ments • Ad din g p erio dic op eration and maintenance requirements for UST systems • Addressing UST systems deferred in the 1988 UST regulation • Adding new release prevention and detection technologies • Updating codes of practice • Updating state program approval requirements to incorporate these new changes As of April 11, 2016, when installing or replacing tanks and piping, owners and operators must install secondary contain- ment, which means the tank and piping must have an inner and outer barrier with an interstitial space that is monitored for leaks, and includes containment sumps when those sumps are used for interstitial moni- toring of the piping. Interstitial monitoring must be used as release detection for these new or replaced tanks and piping. Auto- matic line leak detectors are still required for new and replaced pressurized piping. 5 Under-dispenser containment (UDC) for all new dispenser systems must be installed as of April 11, 2016. UDC contain- ment is containment underneath the dis- penser system designed to prevent leaks from the dispenser and piping within or ab ove th e UD C from reachin g s oi l or groundwater. UDC must be liquid-tight on UST regulations in the United States require owners and operators to design, construct, and properly install UST systems in accordance with industry codes and standards, and according to the manufacturer's instructions.

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