Exercise Care In Choosing An Integrity
Assessment Method
You should ask prospective vendors for
documentation showing that their
assessment procedures meet an industry
code of practice or have been successfully
evaluated by a third party. If you have any
doubt, check with others who have used this
integrity assessment vendor and compare
warranties offered by vendors—in short, use
common business sense. Also, contact your
implementing agency for a list of approved
vendor-supplied procedures or additional
guidance.
Corrosion Protection For Piping
Piping also needs corrosion protection. You
can add corrosion protection for piping by
installing new piping that is corrosion
protected or adding cathodic protection to
existing steel piping.
Completing The UST Upgrade
Regulations and industry codes require a
qualified corrosion expert to design,
supervise installation, and inspect CP
systems installed at the UST site. The
system must be operating at all times to
provide protection. The system must be
tested by a qualified CP tester within 6
months of installation and at least every 3
years thereafter. You will need to keep the
results of the last two tests to prove that the
CP is working. In addition, you must inspect
an impressed current system every 60 days
to verify tha't the system is operating
properly. Keep results of your last three
inspections to prove that the impressed
current system is operating properly.
You also need to have leak detection
monitoring for the life of the tank. Once your
tank, piping, spill, and overfill upgrades are
complete, you can start using inventory
control and tank tightness testing every
5 years. After the later of two dates—either
10 years after the tank has corrosion
protection or December 22,1998—you must
start using a monthly leak detection method,
such as automatic tank gauging,
groundwater or vapor monitoring, interstitial
monitoring, or statistical inventory
reconciliation. (However, the period during
which inventory control combined with
tightness testing can be used will be less
than 10 years in those cases in which the
tank had corrosion protection added before
the entire UST system met upgrade
requirements.) Check with your
implementing agency for more specific
guidance on leak detection compliance.
Need More Information?
EPA can provide free, plain-English
booklets on general UST requirements, the
1998 deadline, UST system closure, leak
detection methods, inventory control,
manual tank gauging, and statistical
inventory reconciliation.
To order free booklets, determine if your
tanks need to meet federal UST
requirements, get more information about
UST requirements, or identify state
regulatory authorities call EPA's toll-free
Hotline at 800-424-9346. Remember,
requirements and deadlines may be
different in some states, so check with your
state UST program office.
You can also find UST publications, links to
state regulatory authorities, and other
information on USTs at EPA's Office of
Underground .Storage Tanks Web site at
http://www.epa.gov/OUST/.
United States
Environmental Protection
Agency
EPA 510-F-97-009
August 1997
Solid Waste and Emergency Response (5401 G)
®EPA Are You
Upgrading An
Underground
Storage Tank
System?
Printed on Recycled Paper
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Are You Upgrading An
Underground Storage Tank
System?
Are you responsible for meeting federal
requirements that apply to underground
storage tank (UST) systems storing
petroleum and installed before
December 22,1988? You must take action
on one of the following if your UST system
does not have spill, overfill, and corrosion
protection:
• Replace the old UST with a new one that
has spill, overfill, and corrosion protection;
or
• Properly close the old UST; or
• Upgrade the old UST with spill, overfill,
and corrosion protection.
The federal deadline for taking action on
these choices is December 22, 1998.
However, you should act as soon as
possible to avoid contractor backlogs or
rising costs as the deadline approaches.
If you fail to comply by the deadline you
can be cited for violations and fined.
Continue reading for helpful information on
upgrading your UST.
Adding Spill And Overfill Protection
You must add spill protection by installing a
"spill bucket." A spill bucket is a catchment
basin sealed around the fill pipe and
designed to catch spills from a fuel delivery.
Overfill equipment is designed to restrict or
stop the flow of fuel during delivery before
the tank reaches full capacity. Your UST
needs to have one of the following overfill
protection devices: automatic shutoff device,
overfill alarm, or ball float valve.
Adding Corrosion Protection To Tanks
What do you need to consider when you
add corrosion protection to upgrade the
tank?
First, are you sure your tank does not
already have corrosion protection? Your
tank has corrosion protection if the tank is:
• Completely made of noncorrodible
material, such as fiberglass; or
• Made of steel having a corrosion-resistant
coating and having cathodic protection; or
• Made of steel clad or jacketed with
•noncorrodible material.
If your tank doesn't fit one of these
descriptions, you will need to add corrosion
protection by either lining the interior of the
tank with a noncorrodible material or adding
cathodic protection. Cathodic protection
(CP) systems are of two types: impressed
current or sacrificial anode. Impressed
current systems are most often used when
adding CP to older USTs. You can also
combine lining with CP.
Can Your Tank Have Corrosion
Protection Added?
Before you can internally line a tank or add
CP, you must first have an integrity
assessment of the tank conducted. This
assessment will determine whether the
tank's structure is sound and free of holes.
One way to assess a tank is to have a
human-entry internal inspection of the tank,
during which a trained professional enters
the tank to determine if it can be upgraded.
Additional integrity assessment methods
may be available as alternatives to using
human-entry inspection. You should check
with your implementing agency—usually the
state regulatory authority— to find out which
methods are valid in your area. Alternative
integrity assessment methods fall into two
categories:
• Integrity assessment methods that
comply with a standard code of
practice developed by a nationally
recognized association (such as the
American Society for Testing and
Materials) or independent testing lab.
These methods are usually
technologies—such as corrosion rate
modeling or tank wall thickness
measurement—that are in accordance
with a standard code of practice. Codes of
practice are often updated over time, so
the code used must be the one applicable
at the time the assessment is conducted.
• Vendor-supplied procedures that have
been evaluated and certified by a third
party as meeting criteria for establishing
the integrity of the tank. The "third party
must be independent and have no
financial or organizational conflict of
interest with the vendor. A vendor-
supplied procedure is an application of a
technology, usually marketed as a
patented brand name and procedure.
Once the tank has passed any of the above
integrity assessment methods, you can have
the tank lined, have CP added, or do both.
See the "Need More Information"
section in this leaflet for sources of
answers to such questions as
"Is my tank an'UST'?"
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