. .,. , . .,
•.."•'"•'•• ' ' ' ' EP4 510-K-94-001
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
' '
JJN.-8 1994
..•''' OPPICE OF " ' '•' . -
?OUD WASTE AND EMERGENCY RESPONSE
\V
Mr. John D. Barnes ,
Manager, Government and Public Affairs
Steel Tank Institute
570 OakWqod Road
Lake Zurich, IL 60047 ,
Dear Mr. Barnes: :
In late April 1994, the Steel Tank Institute (STI) 'notified
the Environmental Protection Agency (EPA) of its desire to
withdraw its request for EPA to relax the mandated frequency for
monitoring the cathodic protection of federally regulated sti-P3«
underground storage tanks (USTs) . By return letter the Agency
honored STI's request. The purpose of this letter is to respond
to your letter of May 12, 1994 to Administrator Browner (copy
enclosed) by which STI notified EPA of its desire to continue to
seek relaxation of the federal requirement for monitoring
cathodic protection systems on sti-P3« USTs. This letter also
provides information on the Federal Register Notice of Data
Avaiial?ihl?V' which solicited public comments on this issue and
9n the TiiM nghact study. Enclosed are copies of the £^J
Rpgister • ™<---f ??« and EPA's Comment-Response document. ';
,vrr>^ May 12th letter states "The Notice of Data Availability
(NDA) process was suggested to STI by the EPA Office of
Underground storage Tanks (OUST) as a way to accomplish the
amendment of the monitoring mandate. ..." This statement is
misleading. in response to STI's request for relaxation of the
monitoring requirement, EPA voluntarily chose to publish a NDA as
a mechanism to obtain public comment and a broader perspective on
the technical issue under consideration/ and as one of several
sources of information to be used in the Agency's deliberative
Sn?0;3,^ At n°^i^^S there a Presumption that publishing the
NDA would mean that the Agency intended to relax the requirement
°l ,a it- was a necessary precondition to making such a change
should the Agency decide to do so. , ^
Printed on Recycled bio*'
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r _
We have carefully reviewed STI's arguments, the Tillinghast
study and all other information submitted to the docket as of the
end of January, 1994. The Agency has decided not to take any
action at this time to relax the frequency requirement for
cathodic protection monitoring of sti-P3® tanks.
BACKGROUND
In 1992, STI and its members requested that EPA relax the"
frequency requirement for ongoing cathodic protection monitoring
of certain regulated USTs. This requirement, found at 40 CFR
280.31(b)(1), requires that "all cathodic protection systems must
be tested within 6 months of installation and at least every 3
years thereafter or according to another reasonable time frame
, established by the implementing agency...." STI requested that
EPA, as an implementing agency, alter the required frequency for
sti-P3® tanks to be at the time of installation and subsequently
only after any disturbance of the excaivation into which the tank
had been placed. EPA indicated that it did not have data
sufficient, to support relaxing the requirement at that time.
STI then contracted with Tillinghast, a Towers Perrin
Company, to perform a study of the issue and provide a report of
the findings. EPA, after informing STI of its intentions to do
so, made the report, titled "Evaluation Of The Potential For
External Corrosion And Review Of Cathodic Protection Monitoring
Associated With stiHP3® Underground Storage Tanks,".available to
the public. Although not required to, on October 25, 1993, EPA
published a Notice,of Data Availability in the Federal Register
and requested public comments on the report. The comment
summaries' and EPA's tespouseis provided in the enclosed document.
DISCUSSION
STI and its members asserted that the required frequency for
cathodic protection monitoring of sti-P3® tanks should be relaxed
for the following reasons:
o sti-P3®'s excellent performance record;
o Cathodic protection monitoring duplicates the effort of the
required monthly leak detection checks;
o Regulatory inequity between existing steel tanks without
corrosion protection, which are not subject to the >
requirement, and sti-P3« tanks;
o Periodic deflection monitoring for fiberglass-reinforced
plastic (FRP) tanks is not required;
o Tendency for the monitoring requirement to affect UST
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buyers' choices; , -
o industry's high cost of compliance; and
o Lack of regulatory enforcement efforts directed at cathodic
protection and its monitoring. ••",.•-
EPA's responses are summarized below. For additional
discussion, see the enclosed Comment-Response document.
. . '•>'•,... • • ' * : ' ^
sti-P3®/s performance record ,
The information provided to EPA from STI and other sources
shows that, to date, sti-P3® tanks appear to have a very good
record of not failing due to external corrosion. However, there
are several reasons why the data presented by STI are not
compelling enough to warrant relaxation of the monitoring
requirement at this time. The first is the youth of the
installed sti-P3® tanks relative, to their expected service life.
No sti-P3® tank has been in the ground for a period of time equal
to the current 30-year warranty period. The vast majority of the
more than 200,000 sti-P3® tanks installed are less than nine
^ears old. Though the Tillinghast report provided some
information on older tanks (registered 1970-75), the information
in the report.is largely from the more common younger tanks.
Indeed, compelling data may not exist at this time, due to the
relative youth of the sti-P3® population. Secondly, and
importantly, cathodic protection monitoring data show that eight
percent or more of tanks tested cannot be shown with certainty to
meet the industry standard for cathodic protection. This does
not mean that these tanks are corroding, but it does mean that,
for whatever reason, there is not certainty that they are not.
Finally, as the Tillinghast report and many commenters pointed
cut, pi-oblems with sti-P3® tanks due to external corrosion have
been documented.
Cathodic protection monitoring and the required monthly leak
detection checks > •
I .. - ' . . „
The cathodic protection monitoring requirement, while it
shares some similarities with the leak detection monitoring
requirements, serves a fundamentally different purpose, and
therefore does not duplicate the leak detection effort. Cathodic
protection systems and the requirements for monitoring them are
designed to reduce the likelihood that any release from an UST
will>occur and is, therefore, a method of pollution prevention.
Leak detection monitoring helps reduce the chances that a leak
will become significant, but in general is not designed to reduce
the likelihood of a leak.
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Regulatory requirements for existing steel tanks without
corrosion protection and for cathodicallv protected USTs
While it is true that the UST regulations do not require
monitoring of existing steel tanks without corrosion protection
("bare steel tanks") and that they can continue in service until
1998, this does not warrant relaxation of the requirements for
cathodically protected steel tanks. EPA still believes, as it
did when the final technical rule was promulgated in 1988, that
even though bare steel tanks pose a significant environmental
threat, a compliance period of less than 10 years for replacing
or upgrading these tanks was not feasible due to the large
universe of unprotected tanks. The same considerations did not,
and still do not, apply to cathodically protected tanks. No one
contends that there are not enough testers available to meet the
required frequency, and as discussed below, once a tank is
cathodically protected, complying with the monitoring
requirements does not pose an undue burden on the regulated
community. Meanwhile, it is important, for cathodically protected
tanks to be monitored, to ensure that they are indeed protected,
and to ensure that they do not add to the threat already posed by
existing bare steel tanks. EPA also would like to note that any
apparent inequity caused by the monitoring requirement is
diminished by the fact that bare steel tanks must be replaced,
upgraded, or closed by 1998, at significant expense to the owner
or operator, while sti-P3« tanks (with spill and overfill
equipment) need not be.
Deflection monitoring for fiberglass-reinforced Plastic YFRP1
tanks
While it is true that FRP tanks are not subject to ongoing
tank wall deflection monitoring to ensure protection against
structural failure, the Agency believes that this is not a valid
reason to eliminate or reduce the cathodic protection monitoring
requirement for sti-P3« tanks. Tank wall deflection in FRP tanks
is a fundamentally different physical phenomenon froa external
corrosion of steel tanks. Because each tank technology is
different, EPA imposed technical standards which require testing
methods and frequencies specific to the technology used.
Therefore, such comparisons are not persuasive.
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The monitoring requirement and tffif buyers' choie?g
mn .In response to concerns that the cathodic protection
monitoring requirement affects buyers' choices this inll
thL°have'iof tEP\belieV?S it: ^ only ^onrol^everfl'ffc
that have led to changes in the market shares for various
protected steel tanks, STI's proposal
-ReSponrt document, EPA beUevei that
ST?^ •S.TESM; is^r^sstn
monitoring can be viewed, as a benefit -.to^iti" customers
6 " enSU ' ' la"
it
Industry's cost of
i tonrricelvea^i.' tnat^at^^rote^n
i
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Regulatory enforcement efforts direet«ad at cathodic protection
and its monitoring
Enforcement priorities .for UST systems may differ state by
state. However, the extent of current enforcement activity does
not determine the need for cathodic protection monitoring. In
many states, enforcement of the leak detection requirements has
priority over the cathodic protection monitoring requirements,
partly because of the earlier deadlines for all tanks to be in
compliance with the leak detection requirements. However, with
the upcoming 1998 compliance deadline for corrosion protection of
all regulated USTs, the emphasis likely will shift to include
more vigorous enforcement of the cathodic protection monitoring
requirements. EPA believes that cathodic protection monitoring
is an important component of pollution prevention for USTs.
CONCLUSION
In addition to the fact that the Agency is unpersuaded by
STI's arguments addressed above, it is important to note that STI
seeks a relaxation of the monitoring frequency despite the fact
that the Tillinghast report was not able to come to any
conclusion regarding an appropriate frequency. STI's position
that post-installation monitoring should be limited to instances
of disturbance of the excavation, without supporting data and/or
analyses, is unpersuasive. This is because site conditions which
can affect the performance of the anodes can occur or change
without the owner or operator's knowledge (e.g., stray currents
that may overpower anodes). Therefore, absent data that would
alleviate this concern, the Agency cannot say that STI's proposed
frequency would be, as EPA determined in promulgating the current
3-year monitoring frequency, "sufficient to detect any damage or
failure of the system and to take remeidial action in time to
prevent structural failures due to corrosion" (see, 53 FR 37137).
Furthermore, EPA's decision not to relax the cathodic
protection monitoring requirement also is strongly supported by
the fact that several national standards, from both industry and
government, place stricter requirements on cathodic protection
monitoring than do EPA's UST regulations.. Please see the
enclosed table comparing several national standards' cathodic
protection monitoring requirements.
In short, EPA believes that the information before it is not
compelling enough to warrant relaxation of the cathodic
protection monitoring requirement at this time. EPA continues to
believe that steel tanks, protected from corrosion according to
both industry standards and Agency regulations, remain protective
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of human health and the environment. The fact that cathodic
protection monitoring of sti-P3® tanks is possible and required
means that owners and operators are likely t;o make sure that the
environment - and their investment.- remains protected.
A copy of this letter and of EPA's Comment-Response document
will be sent to all those who have expressed interest in this
issue, including those who submitted written comments.
David W. Ziegele, Director
Office of Underground Storage Tanks
Enclosures:
. -• i. May 12, 1994 letter from John Barnes, STI
2. Federal Register Notice of Data Availability
3. EPA Comment-Response document
4. Table of Standards for Cathodiq Protection Monitoring
cc: State UST Program Managers (without Encl. 3) ,
UST/LUST Regional Program Managers x
UST/LUST Regional Branch Chiefs (without Encl. 2 and 3)
Dawn Messier, OGC >
Susan O/Keefe, OECA/RCRA
OUST Management Team (without enclosures)
STIRepl3.WS1 , ^ ••-.., \-' •''
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- • -
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
...... ;;'•;••• APR 28 1994 ' ' WTOOf - ,:
. ' . ••-••- -..-,. SOUO WASTE ANO EMERGENCY
Mr. .Wayne Geyer ...-,. .. RESPONSE
Executive Vice President •-
Steel Tank Institute, >
570 Oakwood Road
Lake Zurich, IL 60047 •' :
Dear Mr. Geyer:" •'•-.'..'. •/.'"' ", . :, , '', '..'.''• .',.'•'•'
Thank you for your letter of April 22, 1994, by which th«
Steel tank Institute withdraws its request for the Environmental
Protection Agency to alter the mandated frequency for monitoring
cathodic protection monitoring of federally-regulated sti-P3
underground storage tanks. By this letter, the Agency honors
your request without prejudice.
David Ziegele, Director
Office of Underground Storage Tanks
cc: EPA UST/LUST Regional Program Managers
EPA UST/LUST Regional Branch Chiefs
EPA Office of General Counsel
State UST Program Managers ('
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Steel Tank Institute
April 22, 1994
Mr. David Ziegle
Director '"•'"; , • .' • .-,..'•• ••, /. V . ', ' ;' - ''
Office of Underground Storage Tanks
Environmental Protection Agency
401 M Street, S.W. (OS-410-WF) .' .-
Washington, D.C. 20460
Dear,Mr. Ziegle:
The Steel Tank Institute requests that the Environmental Protection Agency
Office of Underground Storage Tanks terminate the Federal Register Notice of Data
Availability process as regards the cathodic protection monitoring of the sti-P3*
underground storage tank.
- Thank you.
' - - , , -. " .''"••;''-:-
....-.-. -••• • Sincere!);
Wayne Geyer
Executive V^ce President
Steel Tank Institute '
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Steel Tank Institute
708/438-TANK (8265)
May 12,1994
The Honorable Carol Browner
Administrator ,
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Dear Administrator Browner:
\
On April 22, 1994, the Steel Tank Institute (STI) requested that the
Environmental Protection Agency (EPA) terminate the Federal Register Notice of Data
Availability (NDA) process as regards the cathodic protection monitoring of the sti-P3»
underground storage tank. Please see enclosed letter.
The Notice of Data Availability process was suggested to STI by the EPA Office
of Underground Storage Tanks (OUST) as a way to accomplish the amendment of the
monitoring mandate on the sti-P3* underground storage tank.
It only recently became apparent that STTs goals were not going to be
accomplished through the NDA process... therefore we withdrew our request that the
NDA process move forward. EPA agreed to do so without prejudice. Please see
enclosed letter from David Ziegele, Director of OUST.
The purpose of this letter is to notify your office that STI continues to seek the
amendment of the cathodic protection monitoring mandate on the sti-P3* underground
storage tank to require a test at the time of installation... or if an excavation is disturbed
by construction or retrofit activity.
The membership of STI looks forward to working with you on this issue. Our
interest is the same as yours... the protection of human health and the environment
!
Sincerely, • , ,
John D. Barnes
Manager of Government and Public Affairs
Steel Tank Institute
- \
cc. Elliott Laws, Assistant Administrator for Solid Waste and Emergency Response
David Ziegele, Director, Office of Underground Storage Tanks
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ENCLOSURE 2 EPA 5TO-Z-93-003
55066
- . Name . , ' . , , i - . '- ,
Gokfce's Texacb .... «„..„« .
Iron S. Light. Inc :.... ..„ '... , '
Jefferson Davis Par. School Board .-„. """"
Jones Texaco Service :.. , '"" '
Lehigh Portland Cement Company : t - ............
Mohav* Rubber Company : '....
Petroleum Products, Inc : ;
Siders Texaco Station ;.... '- • „.
Spreckles Sugar Co ..............
SRO Paving, Inc . .
Village of Oak Lawn ;
Wythe County Public School ....:...., ..................
.Case No.
RF321-17189
RF272-87063
RF300-II8479
Hr272-87385
RF321 -16997
Hroi^iu203
RF272-86061
RF321-16945
nr321-16992
nroi^lUSflJK
HrZ/Z— 76151
RF272-«7483
RF272-87P59
Copies of the full text of these
decisions and orders are available in the
Public Reference Room of the Office of
Hearings and Appeals, room 1E-234,
Forrestal Building. 1000 Independence
Avenue. SW,, Washington. DC. 20585.
Monday through Friday, between the
hours of 1 p.m. and 5 p.m., except
federal holidays. They are also available
in Energy Management: Federal Energy
Guidelines, a commercially published
loose leaf reporter system.
Dated: October 19,1993. '
Gmrge B. Breznay,
Director. Office of Hearings and Appeals.
IFR Doc. 93-26173 Filed 10-22-93; 8:45 am)
MLUNO COM 1«M HE
ENVIRONMENTAL PROTECTION
AGENCY
[FRL-4791-5] .
Evaluation of the Potential for External
Corrosion and Review of Cathodic
Protection Monitoring Asaociatad With
stKP3 Underground Storage Tanka
Data Availability
AGENCY: Environmental Protection
Agency.
ACTION: Notice of data availability.
SUMMARY: The Environmental Protection
Agency (EPA) is today publishing a
notice of data availability regarding a
report completed by Tillinghast, a
Towers Perrin Company, on behalf of
the Steel Tank Institute (STI). The
Tillinghast report examine* the
potential for external corrosion of sti-P3
underground storage tanks (USTs) aa
well as owners' and operators' corrosion
monitoring practices for USTs. The
Agency's current regulations for
corrosion monitoring require periodic
post-installation monitoring of
cathodicaJly protected steel
underground storage tanks. The Steel
Tank Institute approached EPA in 1992.
requesting it alter the mandated
monitoring frequency for cathodic
protection monitoring of steel USTs.
and specifically, USTs manufactured by
STI members under the "sti-P3"
specification. EPA responded by
agreeing to consider data supplied by an
independent, third-party examination of
STI's initial findings, as part of an
overall data collection process. This
notice summarizes the methodology.
findings, and conclusions of the study.
EPA encourages public review and
comment on the Tillinghast report, as it
may be used in arriving at a final
determination regarding STI's request
for EPA to modify the current
requirements for cathodic protection
monitoring for steel underground '
storage tanks.
DATES: Written comments on this notice
must be submitted on or before
December 27.1993. '
ADDRESSES: Written comments on
today's supplemental notice should be
addressed to the docket clerk at the
following address: U.S. Environmental
Protection Agency, RCRA Docket (OS-
305). 401 M Street, SW., Washington.
DC 20460. One original and two copies
of comments should be sent and
identified by regulatory docket reference
number UST 2-9. The docket is open
from 9 a.m. to 4 p.m., Monday through
Friday, excluding Federal holidays. -
Docket materials may be reviewed by
appointment by calling (202) 260-9327.
Copies of docket materials may be made
at no COSt, With a mayiimim of 100
pages of material from any one
regulatory docket. Additional copies are
$0.15 per page. For a copy of the
Tillinghast report, contact the EPA
RCRA Docket
FC« FURTHER MFORMATON CONTACT: For
general information about this
supplemental notice, contact the RCRA/
Superfund/OUST Hotline, Office of
Solid Waste and Emergency Response,
U.S. Environmental Protection Agency
Washington. DC 20460. (800) 424-9346
(toll-free) or (703) 412-9810 (local). For
the hearing impaired, the number is
(800) 553-7672 (toll-free). For further
information, contact Amy Hazeltine in
the Office of Underground Storage
Tanks at (703) 308-8898.
SUPPLEMENTARY INFORMATION:
L Background ,
A. Technical Requirements for
Underground Storage Tanks
Final regulations for Underground
Storage Tanks (USTs) containing
regulated substances were promulgated
by the Agency in September and
October, 1988 and became effective in
December, 1988 and January. 1989. The
regulations include technical
requirements for new and existing
underground storage tanks and piping,
financial responsibility requirements for
UST owners and operators, and state
program approval requirements. In
order to prevent releases, EPA included
in the technical requirements four
important categories of preventative
measures: (1) Tank design and
installation. (2) release detection. (3)
corrosion protection, and (4) spill and
overfill control. All UST systems
installed after December 22.1988 must
meet Federal requirements immediately.
Owners of tank systems installed on or
before that date have until December 22.
1998 to either upgrade their tanks with
corrosion protection and spill.and
overfill devices, replace them with new
tank systems, or close them in
accordance with the regulatory -
requirements. ,
, According to a study conducted for
EPA in 1987, corrosion of tanks and
piping was a major cause of UST system
releases. At that time, most installed
USTs and piping were constructed of
"bare steel"—steel without corrosion
protection. When buried in the ground.
steel without corrosion protection can
be destroyed by external corrosion.
resulting in leaks. One type of corrosion
protection is cathodic protection, which
is a technique to prevent corrosion of a
surface by making that surface the
cathode of an electrochemical cell. For
UST systems, this can be done by
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Federal Register / Vol. 58. No. 204 / Monday, October 25. 1993 / Notices 55067
applying either galvanic anodes or
impressed electric current.
The UST regulations include
requirements for the operation and
maintenance of corrosion protection of
steel UST systems. As part of these
requirements, owners and operators of
steel UST systems equipped with
cathodic protection must ensure that all
cathodic protection systems are tested
within 6 months of installation and at
least every 3 years thereafter, or
according to another reasonable time
frame established by the implementing
agency. See 40 CFR 280.31(b)(l). The
Preamble to the rule noted that, after
consultation with groups of industry
experts during the public comment
period, EPA now agrees with the
commenters who recommended that all
cathodic protection systems should be
tested at the same frequency and the
Agency is now requiring in the final
rule that all cathodic protection systems
be tested within 6 months of installation
and at least every 3 years thereafter.
These intervals are sufficient to detect
any damage or failure of the system and
to tak«,remedial action in time to '
prevent structural failures due to
corrosion. EPA understands that this
time interval is consistent with sound
practice as is now recommended in the
recently revised NACE (National
Association of Corrosion Engineers)
code and by major tank manufacturers.
See 53 FR 37137.
5. Steel Tank Institute Request and
Study Report
The Steel Tank Institute (STT) is a
trade organization comprised of steel
tank manufacturers. STI members
manufacture pra-«ngineered
underground storage tanks built to the
"sti-P3" specification, for storage of
liquids at atmospheric pressure. Tanks
meeting the sti-P3 specification employ
three types of corrosion protection: (1)
Dielectric coating, (2) electrical
isolation, and (3) cathodic protection
through factory-installed anodes. More
than 200,000 sti-P3 tanks haw been
fabricated and placed in use since 1969.
the vast majority sine* 1985, and they
are commonly installed today.
Single-wall sti-P3 tanks in service for
storage of Federally regulated
substance* ere covered by ta» cathodic
protection monitoring requirements
outlined above. Those tank owners who
installed »ti-P3 tanks in Federally
regulated service between late 1988 and
February of 1993 were eligible to enroll
in SITs "Watchdog" cathodic
protection monitoring service. The
Watchdog service, performed through
STI, provides cathodic protection
monitoring in compliance with the EPA
requirements. Since February of 1993, a
simplified, user-friendly cathodic
protection monitoring test system with
a buried reference cell is installed with
new sti-P3 tanks subject to Federal UST
regulations. Those sti-P3 systems
installed prior to 1988 have been
operated without cathodic protection
monitoring in most cases.
In the spring of 1992. STI requested
that EPA alter the frequency of cathodic
protection monitoring from the current
requirements, to monitoring within 6
months of installation and subsequently
only after any disturbance of the
excavation (e.g., retrofit of Stage II vapor
recovery systems). Periodic monitoring
would therefore not be required. STI
provided data on the performance of sti-
P3 tanks and on potential costs for
cathodic protection monitoring of sti-P3
tanks in support of its request.
STI and its members believe that the
mandated frequency for cathodic
'protection monitoring should be
changed for the following reasons:
* The sti-P3 tank has a very good
performance record;
* The much more frequent monthly
leak detection checks required by the
UST regulations supersede the need for
cathodic protection monitoring;
• There is inequity in that thousands
of existing steel tanks without corrosion
protection, which are much more likely
to fail before phase-out in 1998, are not
subject to the cathodic protoction
monitoring requirement;
* Periodic tank deflection monitoring
for fiberglass-reinforced plastic (FRP) „
tanks was not required in EPA's UST
regulations due to the low incidence of
failure in FRP tanks (less than 0.5
percent), and sti-P3 tanks have similarly
low failure rates;
* UST buyers consider cathodic
protection monitoring and the
associated recordkeeping required with
steel tanks to be an inconvenience, and
this affects buyers' choices among UST
technologies;
• There is a high cost of compliance
to industry; and
• Regulatory enforcement efforts are
directed at clean-ups and loak detection.
not cathodic protection—an indicator
that monitoring cathodic protection is
not an essential activity towards
protecting human health and the
environment
The Agency took no regulatory action
in response to STTs request and the
supporting information. STI asked
TUlingbast. an international risk
management and actuarial consulting
firm with experience in underground
storage issues, to conduct an
independent, third-parry audit of STTs
data. In May of 1993. STI provided the
Agency with a report prepared by
Tillinghast titled "Evaluation Of The
Potential For External Corrosion And
Review Of Cathodic Protection
Monitoring Associated With sti-P3
Underground Storage Tanks." An
abstract of the report follows.
The pollution prevention components
of the UST regulations (including
corrosion protection) are very important
to the UST program. Therefore, the
Agency has decided to publish this
Notice of Data Availability and solicit
public comment on the report to ensure
a more complete understanding of the
issue at hand. This Notice includes
several questions to help guide public
discussion. The Agency is interested in
responses to any of the questions listed
below, and other issues the public may
identify, such as the costs/benefits of
the monitoring requirement itself.
H. Abstract
In May 1993, Tillinghast completed a
study on behalf of the Steel Tank
Institute (STI) which surveyed tank
owners, tank installers, and regulators to
identify any instances of failures of sti-
P3 tanks attributed to external corrosion
and to obtain experience information on
cathodic protection monitoring
practices. A summary of Tillinghast's
methodology, findings, and conclusions
follows.
Methodology
Tillinghast telephone-surveyed
randomly selected sti-P3 underground
storage tank (UST) owners and tank
installers as well as Federal and State
UST regulators about the condition and
general maintenance of sti-P3 tanks.
These individuals, along with data from
the STI Watchdog program (a corrosion
monitoring program initiated by STI in
1988 to assist tank owners in complying
with EPA corrosion monitoring
requirements) provided information on
the frequency, conditions, and other
aspects of the cathodic protection
monitoring practices for sti-P3 tanks. In
addition, the survey sought performance
history on sti-P3 tanks which were not
subject to cathodic protection testing.
Tillinghast also examined
environmental impairment, warranty.
and product liability insurance claims
from the Steel Tank Insurance Company
(SnCO. a captive Insurance company
formed by steel tank manufacturers).
Tillinghaet selected a sample of
owners and installers through STTa
computer data base containing over
200.000 registered tanks. The sample
covered the following nine states:
Washington. Virginia. Vermont. South
Dakota. Colorado. Florida. Texas.
Missouri and Kentucky. The nine states
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Federal Register / Vol. 58. No. 204 / Monday. October 25. 1993 / Notices
represented a variety of climates, tank
environments, saturation periods, water
tables, and soil conditions. Tillinghast's
sample also included a variety of tank
' sizes (from 500 to 20.000 gallons) and
contained petroleum marketers and
non-marketers. Tillinghast examined the
following registration periods: 1970-75,
-1980-41..1985. and 1990. The examined
registration periods began in 1970 when
sti-P3 tanks first became well known to
owners/operators and continue to the
present.
, Tillinghast successfully contacted 110
owners with immediate supervision
over 385 sti-P3 tanks and secondary
responsibility for approximately 2500
sti-P3 tanks at other locations. In
addition, researchers contacted 37
installers throughout the geographic
sample who had experience in over
5000 sti-P3 tank installations. Finally.
Tillinghast contacted the Environmental
Protection Agency's ten Regional UST
offices as well as each of the nine State
UST regulatory offices included in the
sample.
Tillinghast obtained summary
information on 103 environmental
impairment and product liability
insurance closed claims for sti-P3 tanks
from STICO to identify any instances
where payment was made due to a
product release. Tillinghast also
randomly selected eight of the 103
claims to specifically review the "cause
of incident" data.
Findings
Tillinghast identified findings related
to the following areas: Testing of,
cathodic protection systems, cathodic
protection monitoring practices,
environmental and product liability
claims, and understanding of and
compliance with EPA's technical
requirements.
Tillinghast's survey of tank owners
and installers covered over 8,000 sti-P3
tanks. Within the surveyed population,
respondents reported three instances of
sti-P3 tank external corrosion—one of
which involved a product release. Of
the regulators Tillinghast surveyed,
those who had witnessed the removal of
sti-P3 tanks reported that the tanks and
sacrificial anodes were in "excellent
condition upon removal." Regulators
did not provide information on the ages
of the tanks that were considered to be
in "excellent condition upon removal."
Tillinghast reported that corrosion
monitoring requirements (and the
technical basis for those requirements)
are not well understood by most tank
owners, installers, or regulators.
Furthermore. Tillinghast reported that
unless an sti-P3 owner/installer signed
up for STI's Watchdog.program.
cathodic: protection monitoring for sti-
P3 tanks installed since the
promulgation of EPA's technical
regulations was generally not being
performed, although some large sti-P3
tanks users did perform independent
testing.
Tillinghast's review of data from STI
and from owners' research indicated
that test variability can be high for
corrosion monitoring tests conducted on
any given site. Watchdog participants
and major oil companies (many of
whom conduct their own corrosion
monitoring) reported few readings less
than the 850 millivolt compliance point
for corrosion monitoring. Tillinghast
identified human error (in tank
installation or testing) as one cause for
obtaining disreputable corrosion
monitoring results. Unusually dry soil
conditions and other physical factors
also influenced the accuracy of cathodic
protection system testing.
Tillinghast,obtained data from
installers, tank owners, and major oil
companies on the annual cost of
corrosion monitoring. The data showed
the annual cost of corrosion monitoring
to range from $130 to $500 per location
(each location having an average of 3.2
tanks). The impact of these costs was
greatest on small, single location owners,
due to the necessity of hiring a
contractor to travel to the site to perform
the monitoring.
Tillinghast's investigation of STICO
limited warranty and environmental
and product liability insurance closed
claims revealed that most of the sti-P3
claims that entailed both administrative
and investigative costs involved
improper installation techniques or
errors in tank manufacturing
workmanship. Fifty-six of the 103
claims incurred administrative expense
but no claims costs or expenses, leaving
47 others which incurred some sort of
investigative cost (e.g., tightness test).
Only four of the 47 incidents in which
investigative cost was incurred actually
involved a claims payment. Tillinghast's
review of eight randomly chosen closed
claims for "causa of incident" data
demonstrated that a pattern of faulty
workmanship, bad installation, or a .
combination of both resulted in
corroded sti-P3 tanks. .
Conclusions
Tillinghast found no instances of
external corrosion of sti-P3 tanks that
had been properly fabricated,
transported, and installed. Of tha more
than 8000 sti-P3 tank installations
represented by owners and installers,
only three instances of external
corrosion were reported, a frequency of
0.04%, and only one involved a product
release. Tillinghast did not. have enough
corrosion monitoring data to statistically
determine an optimum monitoring
frequency for cathodic protection.
Tillinghast's survey concluded that less
than 10% of the Watchdog participants
or major oil companies who maintain
their own corrosion monitoring .
programs and installed sti-P3 tanks in
1990, reported readings below the 850
millivolt compliance point for corrosion
monitoring. Finally, Watchdog
monitdring data from 1991,1992, and
the first quarter of 1993 indicate that
based on cathodic protection monitoring
readings, the number of sti-P3 tanks
with cathodic protection readings of
- 850 millivolts or greater is increasing.
in. Public Comments
EPA is interested in any comments
that the public may have on the content
of this report, and is especially
interested in any additional quantitative
data commenters may provide. In
particular, the Agency is interested in
receiving answers to the questions listed
below.
* What data are available that
confirm or refute the report's findings
on corrosion protection of sti-P3 USTs?
In particular, have problems with
corrosion protection (such as external
corrosion) on sti-P3 tanks been
observed? If so, what were the numbers.
types, seventy, and impacts of these
problems? What were the ages of any
sti-P3 tanks with problems with
corrosion protection, and were these
problems caused during, before, or after
installation? What are the sti-P3 label
numbers, if available, for verification
purposes? _
* For any sti-P3 tanks observed to
have problems with corrosion
protection, including tanks and piping,
did cathodic protection monitoring
indicate a lack of protection? If so, when
was a lack of protection found—within
8 months of installation or during a later
test? If monitoring was not performed.
would it have indicated a lack of
protection if it had been done?
•• What data are available addressing
the 'above issues for cathodically
protected steel USTs that are not sti-P3
USTs? If problems were observed, were
they observed with field installed or
with factory installed cathodic
protection systems?
* What information is available
confirming or refuting the study's
representation of the costs and benefits
of cathodic protection monitoring of
UST systems?
* How does the simplified.
permanently installed cathodic
protection monitoring system, now
installed with hew Federally regulated
1S-OCT-S3 JM 1502*7 PO 00000 FrmOOOS
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Federal Register / Vol. 58. No. 204 / Monday. October 25, 1993 / Notices 55069
sti-P3 tanks, change cathodic protection
monitoring practices and its costs and
benefits?
* If the study were performed 10
years later and again 20 years later.
would the findings be expected to be the
same? Why or why not?
* What experiences or studies in
other applications of cathodic
protection may provide insights into the
long-term performance of cathodic
protection on USTs and the costs and
benefits of cathodic protection
monitoring?
IV. Schedule for Final Determination
After review and evaluation of the
public comments on this notice. EPA
will conduct internal deliberations to
arrive at a final determination of the
Agency's position on the required
frequency of cathodic protection
monitoring. The Agency plans to reach
a determination within 120 days after
the conclusion of the comment period.
This determination may take the form of
no action, guidance, changes to the
technical regulations, or some other
regulatory action.
Dated: September 20.1993.
Richard J. Guixaosd,
Acting Assistant Administrator.
|FR Doc. 93-26160 Filed 10-22-93; 8:45 am]
MJJNO coot HM ia r
[Fm.-479»-8]
National Advisory Council for
Environmental Policy and Technology
of th« Policy Integration Project, Lead
Subcommittee; Meeting
AGENCY: Environmental Protection
Agency.
ACDOH: Notica.
SUMMARY: Pursuant to the Federal
Advisory Committee Act (Pub. L. 92-
463) the Environmental Protection
Agency (EPA) gives notice of a meeting
of the Lead Subcommittee of the Policy
Integration Project of the National
Advisory Council for Environmental
Policy and Technology (NACEPT). The
Lead Subcommittee meeting will be
held on November 9th and will discuss
draft-working papers on selected topics,
which will be used as background for
the Subcommittee's Report The
Subcommittee will also receive a
briefing from * representative of the
Occupational Safety and Health
Commission (OSHA) on recent policy
activities related to occupational lead
exposures. The Committee will also be
scheduling its next meeting, which will
be held early in December, 1993. The
purpose of the December meeting will
be to discuss the draft report to be
presented to the EPA Administrator.
DATES: The Subcommittee will meet on
November 9,1993. The meeting will
start at 9 a.m. and end at 4:30 p.m.
ADDRESSES: Hall of States, 444 North
Capitol Street, NW.. Washington. DC
20001-1572.
The meeting is open to the public.
with limited seating available on a first-
come, first-served basis.
FOR FURTHER INFORMATION CONTACT: Mr.
Robert L. Hardaker, Designated Federal
Office. U.S. EPA. Office of Cooperative
Environmental Management, telephone
(202) 260-9741.
Dated: October 20.1993.
Robert L. HinUker,
Designated Federal Official, NACEPT-Lead
Subcommittee.
|FR Doc. 93-26161 Filed 10-22-93; 8:45 am)
SCUNQ COM WiO-40-*l
FEDERAL COMMUNICATIONS
COMMISSION
Public Information Collections
Approved by Office of Management
and Budget
The Federal Communications
Commission (FCC) has received Office
of Management and Budget (OMB)
approval for the following public
information collections pursuant to the
Paperwork Reduction Act of 1980, Pub.
L. 96-511. For further information
contact Shoko B. Hair, Federal
Communications Commission, (202)
632-6934. .
Federal Communications Commission
OMB Control No.: 3060-0515
Title: Miscellaneous Common Carrier
and Record Carrier Annual Letter
Filing Requirement—Section 43.21(d)
Expiration Date: 09/30/95
Estimated Annual Burden: 33 total
hours; 1.43 hours per response.
Description: Pursuant to 47 CFR
43.21 (d) each miscellaneous common
carrier with operating revenues over
S100 million for a calendar year shall
file with the Common Carrier Bureau
Chief a letter showing its operating
revenues for that year and the value
of its total communications plant at
the end of that year. Each record
carrier with operating revenues over
$75 million for a calendar year shall
file a letter showing selected income
statement and balance shnet items for
that year with the Common Carrier
Bureau Chief. These letters must be
filed by March 31 of the following
year.
OMB Control No.: 3060-0470
Title: Computer III Remand Proceedings:
Bell Operating Company Safeguards
and Tier 1 Local Exchange Company
Safeguards, (CC Docket No. 90-623)
and Implementation of Further Cost
Allocation Uniformity (MO&O).
Expiration Date: 07/31/95
Estimated Annual Burden: 27.000 total
hours; 300 hours per response.
Description: Section 64.903 of the
Commission's rules requires local
exchange carriers with annual
operating revenues of $100 million or
more to file cost allocation manuals.
The manuals are used by Commission
staff to detect improper cross-
subsidization. In the Memorandum
Opinion and Order (MO&O) in AAD
92-42, (released 7/1/93), the Acting
Chief, Common Carrier Bureau under
delegated authority implemented cost
allocation uniformity requirements.
The MO&O clarifies distinction
among apportionment methods;
establishes a minimum number of
cost pools for ten accounts;
standardizes allocation procedures for
, those accounts; disaggregates
mandated cost pools into additional
pools; and, sets implementation.
Local exchange carriers are required
to file a revised cost allocation
manual by 11/1/93 pursuant to the
requirements contained in the MO&O
and in Responsible Accounting
Officer Letter No. 19.
OMB Control No.: 3060-0400
Title: Tariff Review Plan
Expiration Date: 06/30/96
Estimated Annual Burden: 1.640 total
hours; 40 hours per response.
Description: Certain local exchange
carriers are required annually to
submit a Tariff Review Plan in partial
fulfillment of cost supported material
required by 47 CFR part 61. The
information is used by FCC and the
public to determine the justness and
reasonableness of rates, terms and
conditions in tariffs as required by the
Communications Act of 1934, as
amended.
OMB Control No.: 3060-0484
Title: Amendment of Part 63 of the
Commission's Rules to Provide for
Notification by Common Carriers of
Service Disruptions (Section 63.100)
Expiration Date: 06/30/96
Estimated Annual Burden: 129 total
hours; 2.3 hours per response.
Description: Section 63.100 of the
Commission's rules requires that local
exchange and interexchange common
carriers that operate either
transmission or switching facilities
file service disruption reports
whenever telephone services
provided by their networks are
14,36 OdZZ. 1993 V«O*M 1S-OCT-03 Jkt 15Q2S7 PQ 00000 Fim 00033 F« 4703 SIM «703 E:\FRIFMIP2SOC3-PT1 (XmO4
-------
ENCLOSURE. 3
SUMMARY OF COMMENTS AND EPA RESPONSES
Notice of Data Availability in the fsdeiaj RjaflisiflL October 25, 1993
n hl-rf* Af "£V rece**d "^
pubhshed m the fs^raj flMJaXtt. October 25, 1 993. In general, the commented*
represent the manufacturers, distributors, and installers from the steel tank petroleum
era * C0mp°site tank industries: - A list of the comments is
. The comment summaries and EPA's responses are organized into seven sections
The organization of the document is provided below.. • sections.
1 . - General Support and Opposition to Changing the Cathodic Protection
Monitoring Requirement ;" .' - '. • c>-i UH
1.1. Changing the Tank Design Standards and Associated
Monitoring Requirements
•;.,'. 1.2 Installation Errors. Necessitate Monitoring •-'•. •• ' :
1.2.1 General Installation Error . :
, 1.2.2 Pre-engineered Cathodic Protection Systems and
Installation of Anodes . -
; 1.3 Changing Site Conditions Necessitate Monitoring ,
, 1.4 Specific Tank Data Provided
..." 1-4.1 Data on Cathodic Protection Systems
1-4.2 Data on sti-P3* Tanks
2. Validity of Tillinghast Report ' s ' •
3. Inequality of Rules - Applicability to Other Tanks
4. Duplication of Leak Detection Requirements
5. Ease and Costs of Compliance
5.1 Ease of Cathodic Protection Monitoring
5.2 Cost of Cathodic Protection Testing
5.3 Costs of Cathodic .Protection Monitoring Systems Affects
-; Consumer Choices
c^hQ^^
Relax the Required Monitoring Frequency '
6.1 Enforcement of the Monitoring Requirement Would
Enhance Owners' and Operators' Ability to Comply
with the Requirement > -' .. .
.7. Miscellaneous Issues
-------
1. General Support or Opposition
t . , ,-,--
One commenter (Corrosion Associated, IncJ feels that the impetus for revising the
current monitoring requirement has been pressure from lobbyists who are trying to sell
more steel tanks. He cautions the Agency to get input on the matter from corrosion
experts. One commenter (Fiberglass Petroleum Tank & Piping Institute) implies that some
of the impetus for the request to modify the monitoring requirement has been declining
sales of sti-P3« tanks. The commenter argues that the Agency should not consider the
Steel Tank Institute's request for elimination of cathodic protection monitoring
requirements because its mission is to protect health and the environment, not to protect
one product from competition. • .
c ,•* IA commenters Corrosion Associates, Inc.; Association of State and Territorial
Solid Waste Management Officials [ASTSWMOD noted that the sti-P3* tanks are still new
?MA^C , 'eakS dUe t0 corrosion have no< b«en a big problem. Another commenter
(NACE International) adds that its experience indicates that the average time between
installation and failure of unprotected bare steel tanks is between eight and 1 2 years The
commenter feels that it is possible that more sti-P3* tank failures will occur in the next
few yearg. Another commenter (New York State Department of Environmental
Conservation) indicated that problems with bare steel tanks generally take 18 years to
.become evident. The commenter suggested that sti-P3« tanks have not yet been time
tested, and that problems with the tanks will very likely occur in .approximately 10 years
One commenter (Marcel Moreau Associates) noted that a proper assessment of the tanks'
performance cannot be made until the tanks have been in the ground for approximately 20
years. All of these commenters argued that continued monitoring is necessary until sti-
P3" tanks have been time tested.
One commenter (Fiberglass Petroleum Tank & Pipe Institute) says that the
Tillmgnast report does not say whether tanks will be able to resist corrosion over the 30-
year tank design life. Only 53 of the 384 tanks in the sample were over ten years old
The commenter notes that even bare steel tanks generally do not: develop corrosion
failures for at least 10 years. The commenter therefore feels that the Tillinghast report
does not prove anything. ,
Many commenters' stated that the Steel Tank Institute gives a 30-year warranty
on the sti-P3® tanks. These commenters felt that the length df this warranty indicates the
soundness and dependability of the sti-P3® tank. However, another commenter (Xerxes
Corporation) states that the Steel Tank Institute's 30 year guarantee is immaterial to
whether cathodic protection should be monitored. This commenter argues that the
cathod.c protection system is on the tank to insure that the tank fulfills this service life
and the monitoring is designed to audit the functioning of the cathodic protection system
Another commenter (Green Environmental & Corrosion, Inc.) states that from an
engineering perspective, all engineered systems, .including all tank technologies, require
monitoring.
Another commenter (Fiberglass Petroleum Tank & Pipe Institute) provided copies of
six articles published in the last few years in Tank Talk, a Steel Tank Institute-published
-------
newsletter about USTs. Collectively, the articles show that the Steel Tank Institute has in
tne past supported cathodic protection monitoring as an effective, inexpensive means of
preventing leaks, This commenter notes that many national standards support cathodic
prptect.on monitoring. The standards cited by .the commenter were: NACE International
Canadian Council of Ministers of the Environment, National Standard of Canada Petroleum
Equipment institute, American Petroleum Institute, National Fire Protection Association
and t_he Uniform Fire Code. The commenter notes that there .are two significant areas in
which the. Agency's requirements are more lenient than the majority of these standards
First.- the Agency insists on monitoring of the cathodic protection system within six
months of installation. However, six of the seven aforementioned standards suggest
mon, ormg at installation, while API suggests monitoring six to 'twelve weeks after
•nsta la ion. Second the Agency, is more lenient in its requirements for monitoring during
the .hfetime of a tank: F.ve of the seven standards suggest annual monitoring, while the
Na lonal Standard of Canada suggests monitoring every two years. (Timing of post-
installation mon.tor.ng requirements were not cited for the seventh standard ) The
commenter also notes that the U.S. Department of Transportation supports annual
™°'n cath°dic protection systems used to; protect petroleum pipelines in this
' •Fiber9laSS-Retr0leum Tank'& pipe Institute) ;also cites papers from
ma:rtt !xper^tresses that cathodic protection is inexpensive and easy to -•
m'uM JT-, T P°intS °Ut that beC3USe n° tankS °r Pipe coatina-s are Perf*ct, they
- ""* cathodic P^^ion. This expert states that without adequate
P«tect.on may not continue to function. Another expert reports that
oa m °r 3 ca?odic P^tection system is necessary because the external
coating may deteriorate or become damaged. ... ; , .. ' ' ' •• ,
Petroleum Tank & ?** Institute) noted that the •
coating on an sti-P3* tank, which is 30 mil thick, is much thinner than
he ftberg ass coating on a steel-clad tank, and thinner than a fiberglass-reinforced^aS
oro^am ar. ?hTJntef ^^^ that cathodic *"**<*<>" ^vices and a frequent monLing
an ^^ ? £nfc necessarV to ensur« '^9 term environmental protection when using
conHHr?^0^6™6' (N°rthea^ Utilities Servjce Company) notes that his company
conducts monthly tests of the rectifier (the device that powers impressed systems by
^rnT9 a r^9 CUrrem t0 dif8Ct CUrrent) for ^P^ssed current cathodfcpT^ection
Tht rnm • > aS annUa' teStS °f the entire SYStem for imP^ssed and galvanic systems >
The commented company operates many diverse types of equipment, including
arntT^ate V 1°° UST SVStefnS- During the past f°^ -vears. the commenter has
wpn/' *aPSr°Kimately 5Q Cath°dic Pf0tection P^blems on all types of equpmem.
twenty of which were associated with UST systems. The commenter notes that all of the
problems were identified during routine monthly or, annual inspections, but thatlhese
problems would not have been identified under STI's proposal to decrease
requirement to at time of installation and after disturbance of the UST
-------
Several commenters (Corrosion Control Specialists, Inc.; Owens-Corning Fiberglass
Corporation; NACE International) stated that inspections of the cathodic protection system
should be performed annually by a qualified corrosion engineer.
._ Several commenters (Pump Masters, Inc.; The Coen Company) suggested that,
based on their experience with several sti-P3® tanks each, the monitoring interval should >
be extended. One commenter (Pump Masters, Inc.) suggested that monitoring Be
performed at 10-year intervals, while another (The Coen Company) suggested monitoring
the cathodes every five or ,10 years in some soil conditions.
One commenter (Chem Met, Ltd., P.C.) suggested that if the monitoring interval' is
to be extended, the present schedule should be maintained for the initial five years, and
then extended in individual circumstances if experience shows that the system is being •'
properly maintained and monitored.
f , ,
Another commenter (Beth Anderson) feels that requiring corrosion protection
testing every three -years for tanks may be excessive, but feels that the requirement for
corrosion protection testing of steel piping should not be eliminated. The commenter
bases this opinion on her own experience that pipes are often the cause of LIST releases
and on the fact that the Tillinghast report did not appear to include a consideration of steel
piping. , •
One commenter (New York State Department of Environmental Conservation) also
indicated that if sti-P3« tanks were exempted from the monitoring requirement, all
cathodically protected tank and piping systems would have to be given the same
exemption. The commenter believes that an exemption for only the sti-P3* tanks would
make it diff.cult to determine which tanks and, piping systems required monitoring and
which did not. , •
Several commenters (New York State Department of "Environmental Conservation-
Letter to David Z.egele.from Anonymous) .noted that anodes have a finite expected life
span. The commenters indicated that the cathodic protection system must be monitored
to determine when the useful life of the anode is over so that the system can be upgraded
to ensure continued protection of the tank. , ,
One commenter (Metal Products Company) feels that for years tank manufacturers
have known how to produce a reliable tank but have chosen not to because consumers
would not buy such an expensive tank. The commenter feels that regulations will lead
people to buy reliable tanks like the sti-P3« tank.
Response
Agency does not Question the general quality or the short-term integrity of sti-
? *?2™ However- the A9ency agrees with commenters who state that the populations
of sti-P3* tanks that were included in the Tillinghast report and those used in UST systems
throughout the country are relatively young. While many commenters noted that st/-P3*
tanks carry a 30-year warranty, because no sti-P3* tanks have yet been in use for 3O
years, the Agency takes the warranty as an indicator of predicted, rather than actual.
-------
performance. While corrosion is a complex process and age is not the sole factor in
determining a tank's likelihood to fail due to external corrosion, the Agency agrees that
age does play a role. The Agency still believes what was stated in the preamble to-the ' "
proposed UST technical rules, that generally "f/Jn order to be effective, these corrosion
protection systems must be inspected and maintained. Corrosion protection systems can
fail in a number of ways. For example, coatings can deteriorate, wire leads to cathodic
Protection can break, sacrificial anodes can be consumed; impressed current can be
shorted or otherwise fail, adequate potential may hot be maintained." See 52 Fed Reg
12706 (1987). This reasoning supported the requirement for monitoring in the final
technical rules promulgated in 1988, and the new information before the Agency does not
lead it to question this finding. The Agency received no compelling data or arguments
demonstrating that sf/-PJ« tank cathodic protection systems can be. shown with certainty
• to. remain protected against both short- and long-term corrosion processes' if unmonitored
and therefore that regular monitoring of cathodic protection systems is unnecessary.
Regarding the comment cautioning the Agency to get input on the matter from
corrosion experts, the Agency agrees that getting such input is wise, and responds that
this was one of the reasons for the Notice of Data Availability and request for comments
Input- from corrosion experts was received and considered. Many experienced '
professionals in the corrosion prevention and control community advoca te periodic
momtonng of cathodic protection systems. In response to the comment arguing that the
Agency should consider protection of health and the environment and not protection of
one product, the Agency responds that the Notice of Data A vailability and request for
pubhc comments were intended in large part to gather information to see if the monitoring
• requirements could be.relaxed without diminishing protection of human health and the
environment. . _ \ ' •'• , ,
While the Agency agrees that any problems with si/,P3*> tanks are more likely to
emerge after the population has aged several more years, the Agency notes that
-commenters. who stated that sti-P3* tanks will fail in increased numbers in the next few
years or about 10 years after installation did not provide data supporting these comments.
The Agency agrees with the commenter who noted that several industry and
government standards for cathodic. protection monitoring are more stringent than EPA's
UST requ,rements. The Agency also, agrees with' this commenter that -corrosion experts
nave advocated monitoring of cathodic protection systems.
The Agency agrees with the. commenters whd suggested that regular monitoring of
any UST corrosion protection system, including the st/-P3*> cathodic protect/on system is
a sound engmeering practice. The Agency acknowledges the comment noting that the
dte/ectr,c coating on an sti-P3* tank is typically much thinner than, and different in
composivon from, the fiberglass in both fiberglass tanks and fiberglass-clad steel tanks
However, this comment, from a fiberglass-centered trade organization, does not provide
information on the performance of this coating. >
Regarding the comments that monitoring of cathodic protection systems should be
performed annually an
-------
requirements, the Tillinghast report, and the Notice of Data Availability; a request for
strengthening requirements is outside the scope of the current discussion. In any event,
the Agency disagrees with these comments on two counts. First, the Agency believes '.
that the 3-year interval remains appropriate for the same reasons discussed in the
preamble to 'the final technical rule, which stated, :'the Agency is now requiring in the final
rule that all cathodic protection systems be tested within 6 months of installation and at
least every 3 years thereafter. These intervals are sufficient to detect any damage or
failure of the system and to take remedial action in time to prevent structural failures due
to corrosion." See 53 Fed. Reg. 37137 (1988). ,
Second, the Agency still believes in the soundness of its decision not to require that
cathodic protection monitoring be condutted solely by corrosion experts. As discussed in
the preamble to the final rule (see 58 Fed. Reg. 37136 (19881), in response to the
Agency's proposal of such a requirement, some "commenters pointed out that the
maintenance, operation, and inspection of an installed cathodic protection system could be
performed by people who have much less training than a corrosion expert. EPA agrees
with these comments, recognizing that most of these inspections are now being
conducted by trained specialists." Comments received in response to this Notice of Data
Availability present no data or arguments thai cause the Agency to question this decision.
While the Agency agrees with the Tillinghast report's finding that variability in cathodic
protection readings is reduced through the use of better protocols, the Agency believes
that requiring that the tester meet the definition of corrosion expert may lead to increased
costs without increasing the protection of human health and the environment.
The Agency has examined commonly accepted industry standards for monitoring, of
cathodic protection systems on underground storage tanks and pipelines. The Agency
found that many nationally held standards are more stringent. This lends further 'support
to EPA's decision not to relax the current requirements.
The Agency disagrees with suggestions of monitoring intervals of five or 10 years
instead of the current three years; these significantly longer intervals may allow steel tanks
whose cathodic protection systems are not functioning properly to suffer external
corrosion and leak. The Agency notes that the pace of external corrosion is highly
dependent on characteristics of the metal structure and also of the surrounding soil, which
vary widely. The Agency also finds the suggestion of extending the monitoring schedule
on a case-by-case basis based on past monitoring non-persuasive. This is because of the
additional risk of external corrosion should the cathodic protection system not continue to
function properly, and also because it would be difficult for owners and operators and for
regulatory personnel to keep track of the various individual schedules and to ascertain the
compliance status of each tank. Similarly, the Agency agrees with the commenter who
believes that an exemption for only sti-P3*> tanks, versus all cathodically protected steel
tanks, would make it difficult to determine .which tanks required monitoring and which did
not.
Regarding the comment on cathodic protection monitoring of steel piping, the
Agency agrees that pipes are often the source of UST releases, but notes that this is
outside the scope of both the Tillinghast report and the Notice of Data Availability.
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The Agency agrees that anodes do have finite fife spans, and notes that life spans
are highly dependent on particular site conditions. The Agency also agrees that the end.of
anode life is one of the conditions that causes monitoring results to not meet the industry
standard for verifying cathodic protection. Appropriate action to determine the cause or
.causes of such non-compliant results should be taken. . .'-'. '
Based, in part on the.relative youth of the sti-P3* tank population' and the stricter
requirements of several national standards, 'the Agency believes that the current
requirement for monitoring of sti-P3* cathodic protection systems should not,be relaxed.
1.1 Changing the Tank Design Standards and Associated Monitoring
Requirements . , :
One commenter (State of Missouri, Department of Natural Resources) feels that
rather than defer cathodic protection testing, a more appropriate approach might be to
expand the rule to require periodic .testing of all types of tanks to ensure continued
performance of critical design parameters within specifications on an annual basis.'This
commenter suggests several requirements, including-testing clad USTs to ensure electrical"
isolation of the inner steel tank from,the surrounding soil, periodic diameter measurements
of FRP tanks, and periodic testing of the inner coating of FRP products. •
Another commenter (ASTSWMO) feels that monitoring other tank systems, in
addition to maintaining the current requirements, should be considered. ',-
• One commenter (K.CL Projects, ltd.) stated that there is a risk of external corrosion
' with fiberglass-clad,steel tanks. This,commenter indicated:that fractures occur when
tanks are dropped or dented during installation, or from stresses resulting from the •
differences in the coefficients of thermal expansion between steel and fiberglass. This
commenter did not, however, offer a recommendation for additional Agency action with
' regard to these tanks. ; .'. •, ' l
1 • ' •'"•'.• ' ' ' - • • • ' • '. ; • 's '' > '' '' ' '
This commenter (KCL Projects Ltd.) alsb state'd that coated tanks approved by
Underwriters Laboratory, such as "subject ,1 746" tanks, have never been required to meet
the same strength or corrosion-resistance standards as non-metallic underground tanks,
and therefore cannot be assumed to offer the same corrosion protection as non-metallic
tanks'. This commenter argued that the Agency should require that every new UST meet
UL standards for Class 16 tanks (nonmetallic units with secondary containment).
Response ''",'.'
These comments are outside the scope of the Agency's request for comments In
the Notice of Data Availability. The Agency explicitly limited its request to the Tillinghast
report and to external corrosion on cathodically protected steel tanks.
; " , ' , ..•","-, '•••- • _ • • '. , , • , I ' '• ; •
In any event, the Agency currently does not have sufficient information to support
a change in the monitoring requirements for other tank technologies at this time. The
Agency does not agree that requiring every new UST to meet UL standards for Class 16
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tanks (nonmetallic units with secondary containment) is necessary to guard against
re/eases.
New steel systems with ongoing corrosion protection, including cathodic protection,
were allowed in EPA's technical rules because such systems have been shown ,to provide
protection from galvanic corrosion, a major cause of failure in USTs. None of the above
comments cause the Agency to question the conclusions in the final technical rules. The
Agency believes that proper use and monitoring of cathodic protection systems adequately
protects human health and the environment.
1.2 Installation Errors Necessitate Monitoring
1.2.1 General Installation Errors. Several commenters (KCL Projects Ltd.;
Owens-Corning Fiberglass Corporation) argued that there is a risk of external corrosion
with sti-P3* tanks. They stated that there is no way to locate fractures in the external
coating surrounding the steel tank. These fractures occur when tanks are dropped or
dented during installation, damaged during shipping, or damaged by improper backfill
support or other improper installation methods. Once the external coating has fractured, it
can peel away from the steel, exposing the steel to the environment and increasing the
likelihood of external corrosion by creating an opportunity for accelerated point corrosion.
Therefore, they concluded that the sti-P3® tank design does not provide absolute
protection against external corrosion, and that cathodic protection systems should be used
and monitoring should be conducted regularly to ensure that the systems are working
properly. ,
One commenter (Owens-Corning Fiberglass Corporation) implied that monitoring of
cathodic protection systems should always be required. The commenter noted, however,
that if monitoring of the anodes was no longer to be required for sti-P3? tanks, the Agency
should consider additional restrictions to ensure that the tank coating is not compromised
prior to or during installation. The commenter proposed that the Agency require (1) spark
testing at the jobsite to detect damage resulting from manufacturing defects and shipping,
(2) the use of "self compacting" gravel backfill that will keep the tank from slumping and
cracking, and (3) integrity testing of the coating.
One commenter (STICO [Steel Tank Insurance Company!) states that it knoWs of
five external corrosion failures of sti-P3« tanks, and that the tanks all shared the
characteristics of improper installation and a lack of monitoring. STICO believes these
failures would have been prevented by proper testing at the time of installation. This
commenter believes that, if properly installed and monitored, sti-P3® tanks provide long-
term corrosion protection.
Many commenters (International Asso'ciation of Tank Testing Professionals; New
York State Department of Environmental Conservation; ASTSWMO; Corrosion Associates,
Inc.; State of Michigan, Department of State Police; Letter to David Ziegele from
Anonymous;.STICO; Pump Masters Inc.; Charles A. Frey; Brown-Minneapoli* Tank;
Highland Tank & Manufacturing Company #7; Green Environmental & Corrosion Inc.;
Northeast Utilities Service Company) stated that failures of sti-P3* tanks result from
improper installation practices that violate the integrity of the cathodic protection system,
• 8 . • ; ." '
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and that damage/to the cathodic protection system is difficult or impossible to detect at
installation. One of these commenters (International Association of Tank Testing •
Professionals)'cited specific examples dfcompromise to the cathodic,protection system,
including damage to, external dielectric coating materials; failure to remove protective
covers from anodes; contacts with piping and other objects during installation;,and
damage to anodes or insulating bushings. These'failures would be detected if proper
installation practices and follow-up cathodic protection system monitoring were employed.
. One of these commenters (Highland Tank & Manufacturing Company #7) suggested
that monitoring.at installation would avoid pptentially litigious situations in which the
installation is complete and the owner must get the installer to correct what is now an
expensive problem. Sometimes the hassle of these situations leads the owner to ignore
the problem. Two of these commenters (Pump Masters, Inc.; Brown-MinneapolisTank) -
suggested that the cathodic protection system be monitored at the time of installation and
any time an excavation is disturbed by construction or retrofit activity, and another
.- commenter (Charles A. Frey) suggested monitoring the cathodic protection system within'
six .weeks of installation. One commenter (Corrosion Associated, Inc.) stated that
monitoring should be conducted one year after Installation. , •
One of these commenters (Northeast Utilities Service Company) notes that even
, when installations are performed properly, cathodic protection systems are often damaged
during backfilling and post-installation work. The .commenter suggests that if the Agency
removes the periodic monitoring requirement but requires monitoring after installation, the
cathodic protection system should be monitored after f.1) backfilling, (2) application of final
grade, and (3) installation of all surface structures. ' ^
Response s '--'-'.
The Agency agrees with commenters who note that problems can result and havis
resulted from improper installation of sti-PS® tanks. Information from many sources,
including the jillinghast report, indicates that, although documented cases of sti-P3* tank
failure due to external corrosion may be infrequent, when such failures occur they can
usually be attributed to installation errors. However, again because of the relative youth of
sti-P3* tanks, the Agency does not believe that this means that causes of external
corrosion other than installation errors are not possible.. In addition, while problems due to
installation errors may be likely to be revealed soon after installation, if there are problems
due to causes materializing after installation, they will come to light later, because the
causes occurred later. This, together with the youth of sti-P39 tanks relative to their
expected service life, leads the Agency to believe that the fact that most problems to date
are from installation errors does not mean that any problems in the future also will be.
The Agency understands that some tank owners or installers perform cathodic
protection monitoring at installation.. The Agency believes that this is a sound engineering
practice that can be of benefit to tank owners and, of course, one that meets the
requirements in EPA's regulation that systems be tested within six months of installation.
The Agency believes its current requirement to monitor the cathodic protection system
within six months of installation is sufficient to detect a, lack of cathodic protection before
external corrosion causes premature failure. The Agency believes that the reasoning in the
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Preamble to the final technical rule, at 53 Fed. Reg. 37137 (1988) remains sound, as it
states "the Agency is now requiring in the final rule that all cathodic protection systems be
tested within 6 months of installation and at least every 3 years thereafter. These
intervals are sufficient to detect any damage or failure of the system and to take remedial
action in time to prevent structural failures due to corrosion."
The Agency believes that cathodic protection monitoring performed at the current
frequency is sufficient, and therefore does not need to be enhanced to require monitoring
at installation. • . • . :
1.2.2 Pre-engineered Cathodic Protection Systems and Installation of
Anodes. Several commenters (Piping and Corrosion Specialties Inc.; Chem Met, Ltd., P.C.)
state that a cathodic protection system must be designed for the actual conditions where
it will be used in order to function properly. The standard, factory-installed cathodic
protection systems furnished by the Steel Tank Institute manufacturers are not designed
for specific job conditions. The commenters feel that a standard design will not work in
every location where it could be installed. One of these commenters (Chem Met, Ltd.,
P.C.) feels that a longer monitoring interval .may not be acceptable in all such cases.
Another commenter (Corrosion Control Specialist Inc.)'stated that he has tested
many sti-P3® tanks that have pre-engineered cathodic protection systems. According to
this commenter, not one tank has been fully cathodically protected without needing to add
anodes to the pre-engineered system. The commenter reports that pre-engineered
cathodic protection systems may not meet the specific conditions at a site, such as soil
resistivity. The commenter stated that although the sti-P3® tank has an excellent coating
system, the failure to monitor for corrosion could eventually lead to a tank failure.
Another commenter (Fiberglass Petroleum Tank & Pipe Institute) notes that the sti-
P3® system is manufactured and sold for universal application. The commenter notes that
many corrosion engineers advocate a.corrosion survey of the tank installation site before
the cathodic protection system is installed in order to insure that the proper anode and '
coating materials will be used. The commenter cites the Underwriters Laboratories
standard UL 1746 as evidence that Underwriters Laboratories recognizes that a standard
pre-engineered cathodic protection system should not be installed in all soil conditions.
The commenter concludes by noting that about half of the soil in the United States is
corrosive, having a 4.000 ohm-cm reading, and implies that the standard sti-P3* tank can
not successfully work in such soil. Therefore, the commenter feels that the Agency
should mandate a six-month monitoring interval for sti-P3® tanks in soil of 4,000 ohm-cm
resistivity.
One of these commenters (Piping and Corrosion Specialties Inc.) states that the
Steel Tank Institute has never used National Association of Corrosion Engineers
recommendations in the design, installation, and testing of their pre-engineered cathodic
protection systems. The commenter notes that the life expectancies of cathodic
protection systems can vary from a few years to several years. The commenter concludes
that periodic testing would be the only way to confirm that the system is operating
properly.
10
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One commenter (Owens-Corning Fiberglass Corporation) submitted a report from
.' Harco Technologies showing that sti-P3* tanks built in the last four years are made with'
zinc anodes, which are weaker than magnesium anodes. The report notes that the zinc
anodes are not field tested, and that much of the successful history of the sti-P.3* tank is
based upon the performance of magnesium anodes in use on older models.
. • Several commenters .(State of Maryland, Maryland Department of the Environment;
Piping and Corrosion Specialties Inc.) noted that-sti-P3® tanks are generally constructed
with anodes made of either zinc or magnesium. These commenters expressed" concern
that installation sites are rarely checked for soil resistivity, the main factor that determines
which type of anode should be used on the iank. The commenters noted that when
anodes are installed in an improper environment, they might initially provide protection,'but
shortly thereafter they may not be useful. The commenters provided the example of a
magnesium anode that is installed in an environment with low soil'resistivity, an
environment in which a zinc anode would be more appropriate. The magnesium anode
would be used up rapidly due to self-corrosion, leaving the tank unprotected. The
commenters also noted that zinc anodes in an environment with high soil resistivity will
only provide adequate protection while the coating surrounding the anode is present.
Once the coating breaks down, the anode cannot supply protective current and the tank
corrodes. The commenters concluded that cathodic protection testing should be continued
to provide a warning when anodes cease to be;effective •
One commenter (Corrosion Associates, Inc.) notes that almost all of the tanks that
he has observed being installed have been equipped with zinc anodes and backfilled with
clean sand or pea gravel, which are high resistivity media. The commenter notes that
some of these tanks lose protective potential after a few years, and he believes this is due
to passivation ,of the zinc anode. The cost of excavation to prove that this is the case is
prohibitive, so often additional magnesium anodes are drilled in to raise the potential to
protective levels. The commenter feels that this is an added expense that would not have
been necessary had magnesium anodes been used in the first place.
Response .
The Agency agrees that various combinations of-site conditions and anode materials
exist at sti-P3*> installations and at installations of other tanks with factory installed
cathodic protection systems. The Agency agrees, with those commenters who recommend
periodic cathodic protection monitoring as the best way to measure protection against
external corrosion at any site regardless of site conditions. The Agency also notes, that
efforts to determine the proper type of anode to use for particular site conditions, such as
pre-installation corrosion surveys, have been performed at sti-P3* installations.
With regard to the commenter who feels that the Agency should mandate a six-
month monitoring interval for sti-P3* tanks in soils of a certain resistivity, the Agency
notes that requests to increase the stringency of the monitoring requirement are outsid*
the scope of STI's request, the Tillinghast study, and the Notice of Data Availability. In
any event, the Agency disagrees with the commenter. The Agency still holds the beliefs
found in the Preamble to the final technical rule at 53 Fed. Reg. 37126 (1988), which
reads, "EPA continues to believe that use of a single resistivity variable is inadequats to
11
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measure the propensity to corrode. * The Agency believes, as stated above, that the three
year interval allows sufficient time to take remedial action in order to prevent failure.
' ' -s.
The Agency acknowledges that the sti-P3* tank design for cathodic protection is a
conservative one, intended to work in a wide variety of conditions. However, the Agency
agrees with commenters who report that anodes can be utilized that may not be
appropriate for all specific site conditions. In addition, the anode selection and design
specifications for factory installed cathodic protection systems that were riot
manufactured to the sti-P39 specification are not known.
Therefore, the Agency believes that variation in site conditions and the potential for
the selection of inappropriate anodes for the cathodic protection system warrant periodic
cathodic protection monitoring of sti-PS* tanks. The Agency believes that this requirement
is equally appropriate for the less-understood, non-sti-P39 cathodically protected steel
tanks as well. . "
1.3 Changing Site Conditions Necessitate Monitoring
Another commenter (Government of the District of Columbia, Environmental
Regulations Administration) noted that anodes corrode in the process of generating
protective current. Generally, an adequately designed anode requires no monitoring in the
early years of service, provided that the cathodic protection system is checked at
installation and there are no structural disturbances during the course of its operation. As
the system gets older than 1 5 years, monitoring is advisable. Another commenter
{Electrochemical Devices, Inc.) also noted that where environmental conditions are
constant and cathodic protection is maintained, tank potentials will not vary for the life of
the anode. This commenter felt that it might be acceptable.to relax the frequency of the
monitoring requirement, although he felt that in general monitoring was a valuable practice
and should be continued. '
Several commenters (Xerxes Corporation; NACE International; Northeast Utilities
Service Company; New York State Department of Environmental Conservation) argued that
changing site conditions justify frequent monitoring. One of these Commenters (Xerxes
Corporation) states that underground conditions constantly change. Corrosion rates rise
and fall as water passes in and out of an area, and the addition of power lines, new
buildings and underground piping near a tank location can create disturbances that damage
cathodic protection systems. This commenter stated that the typical owner may not be
aware of these disturbances, or the damage that they may cause to the corrosion system.
The commenter believes that the frequency of the monitoring requirement ensures that
any compromise in the protection system will be detected in a timely manner.
Another commenter (NACE International) states that there are some specific
reasons to require periodic testing of the cathodic protection system. Those reasons ara:
(1) changes in UST configuration; (2) electrical changes such as stray current/interference,
shorts to other structures, wires cut or damaged, and anodes consumed; (3) environmental
changes such as drainage, earthquakes, settlement, and pollution/contamination; and (4)
nearby effects such as new construction and utility changes or additions.
12
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One commenter (Northeast Utilities Service Company') notes that operators of
: facilities do not always inform parties that monitor cathodic protection systems that a tank
has been disturbed so that they may initiate testing "after the disturbance. Under the
current regulatory schedule, problems of this nature are identified during the next cathodic
protection monitoring.' Without a periodic monitoring requirement, problems caused by
•disturbances may go unnoticed and lead to-possible releases to the environment.
One, commenter (New York State Department of Environmental Conservation) noted
that the Tillinghast report cites an incident of sti-P3® tank failure as a result of a massive
stray current that overpowered the anode. The commenter notes that although the
Tillinghast report attributes most corrosion failures:tOr installation damage or excavation
disturbances, in this case the report does not mention any excavation disturbance
associated with the incident. This commenter concluded that monitoring of the cathodic
protection system would have detected the situation so the owner pr operator could have
taken steps to protect the tank before it corroded and failed.
Response
The Agency believes that the likelihood of changing site, conditions surrounding an
UST,system warrants regular ca.thodic protection monitoring by the owner or operator.
Owners and operators may not be aware of every occasibn when the site conditions
surrounding an UST, or a group of USTs, have been disturbed. Site conditions, and their
effects on ah underground structure's corrosion protection, change for many reasons.
These include heavy rainfall that can increase soil moisture' and therefore the likelihood for
external corrosion. Also relevant are nearby construction activities that can disturb the
soil, leading to accelerated corrosion due to less homogeneous tank backfill. Construction •
, also can short circuit other metal structures to the tank. In this case, anodes* as they
protect more exposed metal, will not last as long as they would otherwise, potentially
leading to external corrosion where none would otherwise occur. In addition, electrical
changes, such as stray currents from electrical utility lines or changes in nearby impressed
current cathodic protection systems, can render a cathodic protection system less
effective. -, '••'".' ; ' •
If the owner or operator does not realize that conditions surrounding the USTs have
changed, the US Ts can become more vulnerable to corrosion and the possibility of a leak.
The Agency believes that owners or operators will know when some changes occur,
including most construction activity disturbing the backfill, but also believes that there are
many opportunities for site conditions to change without the owner or operator realizing
the change has taken place. Furthermore, the Agency believes that, without a schedule,
some owners and operators will, even if they realize changes have taken place, not
properly monitor the cathodic protection system to ensure it is still functioning properly.
Because so many factors that can impact the cathodic protection system are
beyond the control of and can occur without the knowledge of UST owners arid operators.
it is not feasible to rely on owner and operator discretion to determine the appropriate
intervals for monitoring a cathodic protection system. The Agency bet/eves th*t the
current monitoring frequency allows owners and operators to detect changes in the UST
environment that can compromise cathodic protection systems and to take timely and <
: 13 . " ••• • '•" ':•'-.- --' •"' ..: '
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appropriate actions to protect those systems. Finally, the Agency believes it would be
difficult for implementing agencies to monitor compliance with, and enforce, a requirement
to monitor only after site conditions have changed due to construction or another
disturbance of the tank excavation. ' .-
1.4 Specific Tank Data Provided
1.4.1 Data on Cathodic Protection Systems. Several commenters (Owens-
Corning Fiberglass Corporation; Fiberglass Petroleum Tank & Pipe Institute) cited a study
that was conducted from 1980 to 1983 by the PSG/Hinchman Company for Owens-
Corning Fiberglass Corporation. In this study, 76 sti-P3® tanks were tested in four states,
and measurements were made relative to the well-established industry standard criterion
of a negative potential voltage of at least 0.85 volt (-0.85 volt), as measured between the
structure and a saturated copper-copper sulfate half-cell contacting the soil. The
Hinchman Company found that although 63 (83%) of the 76 tanks* were adequately
protected from external corrosion failures, eight (10%) tanks did not meet the selected
criterion for cathodic protection because their insulating bushings were shorted, and five
(7%) tanks did not meet the selected criterion for cathodic protection for unspecified
reasons. These commenters also cited a report (The Geyer Report) that documents the
results of surveys conducted by the Steel Tank Institute during 1986. Data from this
report indicate that 22%2 of 591 tanks surveyed and tested did not meet the industry
standard -0.85 volt criterion, as required in National Association of Corrosion Engineers'
Recommended Practice RP-02-85.
Another commenter (State of Missouri, Department, of Natural Resources) reports
that it has inspection records for 1,962 USTs. Six of these inspections specifically
identified noncompliance with the corrosion protection'requirements. Five of these six
records covered facilities that are believed, based on registration data, to be sti-P3® USTs.
Five of these six records indicate that .the initial violation was the owner's or operator's
failure to test the cathodic protection system. Three of the six records provide test results
indicating ,that cathodic protection systems were not operating properly. % '
Another commenter (State of Maryland, Maryland Department of the Environment)
noted that several corrosion protection companies that test hundreds of tanks per year
across the country report an almost 80% failure rate, of cathodic protection systems when
checked against the -0.85 volt criterion. (The commenter did not state whether the tanks
examined were sti-P3* tanks.) This failure rate implies that most cathodically protected
tanks are not adequately protected against corrosion, and that continued monitoring is the
only way to detect likely problems with the tanks.
Another commenter (Green Environmental & Corrosion, Inc.) notes that her firm
tests a significant number of cathodic protection systems every year. Based on their
results, over 60% of sti-P3® systems do not meet the criteria for cathodic protection. One
commenter (Letter to David Ziegele from Anonymous) notes that he is aware of single wall
sti-P3* tanks originally sold by his company and others that are not cathodically protected
and cannot pass a precision test. .
14
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Another commenter (Beth Anderson)'questions the reliability of sti-P3* tanks that
have ;been in the ground for 20 years or more.. The commenter reports seeing significant
: ..depletion on some cathodic protection systems (i.e., the anode) after 1 5 to 20 years of
service. The commenter notes that in these instances there was no corrosion damage on
the tank, but that the.anodes had been replaced to provide better long-term protection.
the commenter feels that failure to replace the anodesrwould have-put the tanks a't risk of
corroding. . , ' • >. > . '..'• ' , . .'.'-'.
"•* / ' • • - '.'„".* - •
'• One'commenter (ASTSWMO) notes that the Tillinghast report says that less than
-10% of the Watchdog participants of major oil companies who maintain their corrosion
monitoring programs and installed sti-P3* tanks in 1 990 reported^ readings below the -0.85
voJt criterion.••The commenter expresses concern that these tanks are only three to four
years old, and that as many as one in ten are put of compliance with acceptable levels-for
corrosion protection. The commenter notes that, these substandard test levels may be due
to factors other than anode failure, but feels that periodic monitoring of the cathodic
protection system woujd indicate the need for further investigation to determine the cause
of the substandard readings. , •
- ' 1.4.2 Data on sti-P3® Tanks. Several commenters (Fargo. Tank Company;
Pump Masters lnc;; Highland Tank & Manufacturing Company # 13, #12, and #10; E.E,
Wine Inc.) described their experiences with the removal and inspection of sti-P3® tanks.
One of these commenters (Fargo Tank Company) described four sti-P3* tanks that had
been in the ground for more than six years. This commenter reported that the four tanks
showed no internal or external corrosion, pitting or scratching. Another commenter {Pump
Masters, Inc.) described two sti-P3* tanks that had been in the ground for 12 and 14
years respectively. The exterior coatings on the tanks appeared to be in very good . . •
condition,, with'no evidence of peeling or deterioration. Several commenters (Highland
Tank & Manufacturing Company #13; Highland Tank & Manufacturing Company #12)
described the^eondition of several sti-P3* tanks removed after seven and ten years in the
ground by saying that they looked like the day they were installed. Another commenter
(Highland Tank & Manufacturing Company #10) described the condition of an 8,000
gallon, five-year-old sti-P3* tank. The tank had some scratches --in its coating and a light
gray film covering on the area of the scratches. The commenter said the gray film was the
action of the anodes working to protect the scratches and therefore to protect.against
corrosion. Another commenter (E.E. Wine, Inc.) excavated to the .top. of an sti-P3* tank
that had been buried for seven years, and noted that the tank was in good condition.
Several other commenters (James 8. Phillips Company, Inc.; Beaver Petroleum Co.
Inc; Crawford Fuel and Oil; Bell Petroleum Ltd., Aviation Products Division; Fred's
Plumbing and Heating #1; Fred's Plumbing and Heating #2; Sammy L. Thorlup; Benit Fuel
Sales & Service Inc.; Highland Tank & Manufacturing Company #8; Alliance Oil Service •
Company; Baird Petroleum Equipment Corporation; James Islintu) described sti-P3* tanks
based on visual observation during removal. Although the commenters did not provide the
ages of the tanks, they reported that the tank? showed no evidence of corrosion, and that
in some cases original labelling and stencilling were still legible on the external tank
surfaces.
15
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Many commenters3 stated that the sti-P3* tank is an extremely reliable tank.
These commenters stated that based on their experience with installing or using sti-P3«
tanks, they knew of few or no problems associated with the tanks. These commenters
stated that of the more than 200,000 sti-P3« tanks that have been installed, there have
been only seven reported failures. One of these commenters (Highland Tank &
Manufacturing Company #2) stated that although more than 200,000 sti-P3* tanks have
been installed, he only knew of one reported product release from an sti-P3® tank. •
One commenter (Brown-Minneapolis Tank) stated that the Tillinghast report
mentions only two failures out of the 8,000 sti-P3® tanks included in its sample. The
failures of these tanks were due tp improper installation and not the tanks themselves
One commenter (STICO) states that based upon actuarial assessments, the sti-P3«
tank has the lowest insurance premium rate as a result of its comparatively low risk
exposure -- less than 1/10 of 1 % of all sti-P3« tanks fail. He acknowledges that this low
risk exposure is due largely to compliance with the cathodic protection monitoring
requirement to monitor within six months of installation. 'He reports that he knows of five
external corrosion failures of tanks, and that they all shared characteristics --improper
installation and a lack of monitoring on the part of the owner operator -- which he believes
could have been prevented by proper testing at the time of installation. He believes that
sti-P3* tanks provide long-term corrosion protection. , .
Another commenter (Green Environmental & Corrosion, Inc.) notes that the Steel
Tank Institute Watchdog Program was finding a large number of non-compliant cathodic
protection readings. According to the commenter, this lowered owners' faith in the
system, which in turn reduced the number of sti-P3* tanks sold.
Response
In response to concerns about internal corrosion, the Agency points, out that the
Tillinghast report, like external cathodic protection systems, addresses only external
corrosion. In addition, the Agency's information is that internal corrosion of steel tanks
historically poses a much smaller risk of release than external corrosion.
The Agency believes that commenters who cited the Geyer Report as indicating
that 22% of 591 tanks surveyed and tested did not meet the -0.85 volt criterion
misinterpreted the report's findings. Tables 2 and 3 of the Geyer Report show a finding
that 10 or 11%, not 22%, of the universe of 591 tanks surveyed were below the -0 85
volt protection criterion.
The Agency notes that the -0.85 volt potential cathodic protection criterion is a
conservative one that has been documented over many years as providing protection of
steel in a wide variety of conditions. Furthermore, the Agency is aware that site
conditions such as extreme backfill dryness. which renders neither the tank nor the anodes
cathodically active, can cause non-compliant readings. Therefore, readings more positive
than -O.85 volts do not necessarily indicate that a tank is corroding. The Agency notes
that several commenters provided data indicating that a significant fraction of cathodic
protection monitoring is not able to show that the systems monitored are, with certainty.
. 16 ' •'. ' . ' ,
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meeting industry standards. However, the criterion is a well-established industry standard
and its use is a -certain and efficient way to determine that a tank has cathodic protection'
When cathodic protection.systems do hot meet this criterion, owners and operators should
investigate the cause of the failure in order to be able to achieve the standard. The
Agency believes that the current cathodic protection monitoring requirements of •/
monitoring within.six months of installation and at least every three years afterward are
adequate and detect potential failures of cathodic protection systems.
In response to comments on sti-P3* tanks,, the Agency acknowledges that many
expenenced'professionals believe in their reliability. However/few commenters provided
data covering a large number of tanks. These comments do not compel the Agency to
reduce the required frequency of cathodic protection monitoring, due largely to a lack of
adequate data and to the youth of the population of sti-P3*> tanks relative to their exoected
useful life. ;•' ; ., .
17
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2. Validity of Tilllnghast Report
A commenter (State of Michigan, Department of State Police) states that the .
Tillinghast report is based on a sample that contains a disproportionate number of tanks
that were installed after promulgation of the UST rules. This sample, therefore, does not
provide sufficient data for identifying the ideal monitoring schedule. The commenter feels,
that without additional data, there is-not adequate evidence to support any change in the
monitoring requirements. '
Several cdmmenters (Xerxes Corporation; Piping and Corrosion Specialties Inc.)
believe that there is no statistically reliable data to either affirm or refute the Steel Tank
Institute's assertion that the sti-P3® tank has a very good performance record. One
commenter (Xerxes Corporation) notes that much of the information in the report is based
on anecdotal information provided by people who are not aware of the limits of their
knowledge. To be statistically valid, the survey would need to have a broader population
and look at tanks in different soil conditions and of different ages. This commenter also
notes that the survey is full of assumptions, uncertainties, and admissions of deficiencies.
The other commenter (Piping and Corrosion Specialties Inc.) noted that some of the
conclusions in the Tillinghast report are suspect. Specifically, this commenter notes that
the report included only 110 owners who had direct knowledge of 385 tanks and
secondary knowledge of 2,500 tanks, and 37 installers who had knowledge of 5,000
tanks. The report stated that the cathodrc protection requirements are not well
understood by many owners, installers and regulators, and that monitoring of the cathodic
protection system was generally not being performed. This commenter questions how
Tillinghast therefore can conclude that sti-P3* tanks do not need to be monitored when, i
many of those surveyed were not monitoring or did not understand the. cathodic protection
systems.
Another commenter (Green Environmental & Corrosion, Inc.) contends that the
Tillinghast report is not authoritative. The commenter believes that the Tillinghast report is
extremely limited for the purpose of rewriting a federal regulation, and that significantly ;
more information should be obtained. The commenter further notes that the owners of the
tanks surveyed were under the Steel Tank Institute Watchdog Program, and, because they
receive test results under the program, knew the condition of the cathodic protection
systems prior to the survey. They would have been informed of the failure of the cathodic
protection systems and would have taken preemptive measures to avoid damage to their
tanks.
One commenter (Green Environmental & Corrosion, Inc.) stated that the small
number of insurance claims against STICO for sti-P3® tank failures is not a valid indicator
of the rate of sti-P3* tanks failures. This commenter argued that the numbers would not
be valid because many owners would first proceed to their respective state insurance
funds for coverage in the event of a failure and because in some cases STICO has refused
to honor claims made against it due to what it called contractor negligence.
One commenter (Fiberglass Petroleum Tank & Pipe Institute) says that the
Tillinghast report is biased by geographic tank distribution. For example, the sample did
18
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not include any tanks from the midwest (Region 5) and only 1,7% of the tanks selected
were located in the northeast (Regions 1 & 2). the majority of, the tanks in the sample- ''
(50.9%) were located in EPA Regions 6, 7 & 8. "The commenter further noted that the
geographic areas chosen for the sample,are not known to be areas where corrosive soils
' and stray currents are typically found in UST settings. The commenter argued that a
representative,.sample should have included such states as Ohio where cathodic protection
'has been problematic due to low soil resistivity and New Jersey where most USTs are
installed in urban settings subject to stray currents.''In sum, the commenter feels that the
Tillinghast. report sample selection is biased towards sti-'P3® tank locations in the most
favorable soil conditions. The commenter notes, however, that even in these favorable
settings the Tillinghast report shows an unacceptable level of cathodic protection for many'
sti-P3« tanks. • -- • •••'.,.' ... . .
This commenter (Fiberglass Petroleum Tank & Pipe Institute) also stated that the
Tillinghast contacts were not appropriate because they could only produce anecdotal
information. This commenter argues that interviewing 'installers was inappropriate because
it was in. the .installers' best interest not to identify problems with their installations, 'The
commenter further noted that only 11 of the 37 installers interviewed had experience with
sti.-PS® tank removals. This commenter .also questions the validity of interviews with .'•
major oil company representatives. Although' not identified in the Tillinghast report, this
commenter believes these major oil companies had to be Exxon, Chevron, Shell, Texaco,
Mobil and ARCO. This, commenter noted that these companies are all FRP tank users and
have only incidental experience with sti-P3* tanks. The commenter indicated that while
Amoco could also have provided comments, this company has discontinued the use of sti-
P3« tanks and therefore the commenter believes that Tillinghast would not.have
interviewed them for this report. Finally, this commenter noted that the only other
company that could have been included is Marathon, which is owned by USX, a steel
producer. This commenter argued that Marathon's comments would therefore be biased in
.favor of sti-P3® tanks. : ."'';---'
'" ' ' ' ' - - . ' .' " . ''/•••.-
One commenter (Letter to David Ziegele from Anonymous) feels that the only way
to know the truth about sti-P3« tanks is to depose every sti-P3« tank manufacturer under
oath and survey every owner of a cathodically protected, UST.,
Response
The Agency acknowledges the comments regarding the validity of the Tillinghast
Report. In its decisionmakihg process, the Agency has evaluated and considered the data
and information presented in that report and another information submitted to the docket
as of the end of January, 1994, on their own merits. "
The Agency notes that the Tillinghast report is the most comprehensive of its kind
to date, and includes Both 'hard" data, such as that from the Steel Tank Insurance
Company {STICOi, as well as "soft" data, such as estimates from installers and regulators.
The Agency agrees with the comment that the report Is tesed on a sample that contains a
disproportionate number of tanks that were installed after promulgation of the UST rules in
1988. This may well be because the vast majority of sti-P3* tanks have been installed
since 1985. making older sti-P3* tanks and information about them rare. The Agency
• • • • . ' ' --. .-"""• " t " -
' " ••'••;• ••' -• - '• -19 • ''...' ; •"' . /' ' . '• •
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further agrees with this commenter that without such data, there is not adequate evidence
to support any change in the monitoring frequency requirement. The Agency notes that
data of this nature may not be available for several years, due 'to the youth of installed sti-
P39 tanks relative to their expected service life and relative to their current warranty period
of 30 years. Even though age is by no means the sole indicator of tank integrity, corrosion
is progressive and the Agency believes that the fact that relatively few older tanks were
surveyed skews the applicability of the report's findings to the subject of ST/'s request.
The Agency acknowledges the report's findings that there have been very few
recorded failures of sti-P39 tanks, but acknowledges the commenters who stated that no
statistically reliable data was included to affirm the claim that the sti-P39 tank has a very
good performance record to date. The Agency again notes the lack of data from older sti-
P39 tanks. ,
The Agency agrees with the comment noting that much of the information in the
report is anecdotal, and that many of the people providing the information appear to have
little technical knowledge of cathodic protection. The Agency believes that the findings
obtained from these sources are therefore less persuasive than if respondents
demonstrated a high level of technical competence. The Agency agrees with the comment
that the report does have definite limitations, some of which are stated in the report itself:
For example, the report notes that the actual numbers of tanks owned or installed by
survey participants could be 50% higher or lower; thus, Tillinghast rightfully could not
state with reasonable certainty that all instances of external corrosion of sti-P39 tanks
were identified, and also could not state with certainty that the instances that were
identified involved sti-P3* tanks.
The Agency also agrees with one commenter that the report noted that cathodic
protection monitoring is frequently not performed, and therefore any conclusion that sti-
P39 tanks do not need to be monitored is questionable. Furthermore, the Agency agrees
with this commenter that the tank owners surveyed in the Tillinghast report that were
covered by STl's Watchdog program are more likely to knpw the condition of their
cathodic protection systems and to have taken remedial steps in the event of
noncompliant readings. Finally, EPA believes that this commenter's assertion that the
number of claims against STICO is not a valid indicator of sti-P39 failures is plausible,
partly because a large majority of states have funds available for addressing leaks. The
Agency cannot speak to the comment regarding honoring claims and alleged contractor
negligence.
The Agency acknowledges one commenter's claim of geographical bias, and agrees
with this commenter that the Tillinghast report shows that several percent of sti-P3* tanks
tested are not shown to meet industry standards for cathodic protection. Regarding the
interviews of installers, the Agency agrees with this commenter that the report shows only
11 out of 37 installers interviewed had experience with sti-P3* removals, and believes that
information on tank condition at removal is very important with regard to external
corrosion.
The Agency agrees with commenters that some of the sources of information in the
Tillinghast report are not financially independent of the success of sti-P3* tanks, but also
20 ' . , •
-------
notes that this is true of several of the commenters. The Agency has taken into
consideration the apparent interests of those providing information as appropriate
In response to the anonymous commenter. who felt that the only way to know the
truth about st/-P39 tanks was to depose all sti-P3* manufacturers under oath and survey '
all owners of cathodically protected tanks., the Agency believes that such activities would
be very resource intensive and impractical. However, the Agency acknowledges that the
more respondents are surveyed, the greater the level of confidence in the responses, and
.notes that the Tillinghast findings 'are based on surveys of only a small fraction of the
installed sti-PS9 tanks. ' . ' . ^ . '
The Agency acknowledges the report's findings; that almost eight percent of tanks
in the Watchdog program in recent years were not shown to be protected for one .reason
or another, though cathodic protection monitoring results are reported to be improving.
The Agency also acknowledges the report's finding that, unless a tank is in the Watchdog
program or maintained by a major oil company, cathodic protection monitoring is generally
not being performed. The Agency also acknowledges that assessing the frequency of •
cathodic protection testing was not the primary purpose of the report, and that Tillinghast
states that it did not obtain, enough corrosion monitoring data to statistically determine an
optimum monitoring frequency.
Consideration of the Tillinghast report and comments regarding it lead the Agency
to believe that routine cathodic protection monitoring is necessary in determining whether
or not steel tanks are protected from external corrosion, and should still be required.
21
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3. Inequality of Rules - Applicability to Other Tanks
Several commenters (Highland Tank & Manufacturing Company #2, Ten Hoeve
Brothers, Inc. #1) argue that the monitoring requirement is inappropriate because it is not
placed on bare steel tanks and other technologies that are allegedly less proven than the
sti-P3® tank. ' • -,-
Several commenters (Xerxes Corporation; Marcel Moreau Associates; State of •
Michigan, Department of State Police) argue that the cathodic protection monitoring
requirement is not inconsistent with the phase-in schedule for existing UST systems. One
of these commenters (Marcel Moreau Associates) states that the fact that sti-P3« tanks
require cathodic protection monitoring and others do not should not be viewed as unfair.
Rather, the fact that different requirements apply to different tanks should be accepted as
part of the overall regulatory strategy used to ensure the safety of all UST systems by
1998. The commenter adds that sti-P3® tank distributors,could use this argument as a
selling point, promoting their tanks as better protected from leaks than are brands that do
not have to adhere to the monitoring requirements. Another of these commenters (State
of Michigan, Department of State Police) notes that the cathodic protection requirement
for steel tanks is not indicative of a bias toward unprotected steel tanks. Rather, the 1998
phase-in of tank upgrade requirements is intended to minimize the financial burden on the
regulated community for costs associated with upgrading UST systems The other
commenter (Xerxes Corporation) stated that although the requirements appear to be
inequitable with older non-protected tanks, the commenter argues that the customer is
paying for a better product when he buys a cathodically protected steel tank.
Several commenters (Xerxes Corporation; Marcel Moreau Associates; State of
Michigan, Department of State Police) argue that,because periodic monitoring of fiberglass
tank diameters is not required is not a valid reason for eliminating the cathodic protection
monitoring requirement for steel tanks. The commenters contend that the two types of
tanks fail in different ways. Thus, requirements that may be appropriate for steel tanks
may not be appropriate for fiberglass tanks. Another commenter (State of Michigan,
Department of State Police) argues that, although the absence of tank deflection
monitoring requirements for fiberglass-reinforced-plastic tanks supports a lack of tank
deflection monitoring requirements for stee! tanks, the absence of such a requirement does
not justify eliminating the cathodic protection monitoring requirements for steel tanks.
Response
While it is true that cathodic protection monitoring is not required on bare steel
tanks prior to December 22, 1998, this fact does not warrant relaxation of the
requirements for cathodically protected steel tanks. The Agency believes that the
discrepancy in requirements is appropriate. It would have been most environmentally
protective to require immediate upgrading of bare steel tanks. However, the Agency still
supports its original decision, made when the technical rule was promulgated in 1988, to
allow owners of bare steel tanks until 1998 to meet these requirements. This decision
was based on the Agency's conclusion that a shorter compliance period was not feasible,
given the diverse nature and large size of the regulated UST community. Because periodic
:. " 22 ' ' . • ' ' :
-------
cathodic protection monitoring of steel tanks that do not even have cathodic protection
serves no purpose, and because, as stated elsewhere, cathodic protection monitoring is
neither difficult nor expensive', the Agency believes that applying, different standards is
reasonable. .Meanwhile, it is important for cathodically protected tanks to be monitored, to
ensure that they are indeed protected, and to ensure that they do not add to the threat'
posed by existing bare steel tanks. The Agency also notes'that bare steel tanks must be
replaced or upgraded by December 22. 1998. Either of these tasks costs thousands of
dollars. By contrast, tanks with pre-engineered cathodic protection monitoring systems
land spill and overfill equipment! need not be upgraded or replaced.
Although the Agency defined a ten year compliance period for upgrading existing
. bars steel tank systems, it continues to be concerned about their potential impact on
human health and the environment. The Agency notes that it and many state UST - "
programs have encouraged owners and operators to upgrade their existing tank systems
before the 1998 deadline and have seen some progress toward that end. Compliance with
the monitoring requirements for those upgraded or replaced systems has greatly reduced
the incidence of corrosion failure in steel tanks. Given the complex nature and size of the
regulated community, the Agency believes that this combination of requirements has
provided the greatest protection of human health and the environment.
In response to concerns about the inequality of'the rule because it does not apply
to fiberglass tanks, the Agency believes that tank wall deflection in fiberglass tanks is a
fundamentally different physical phenomenon than external corrosion of steel, tanks, both
m its. nature and in its likelihood to pose a threat to tank integrity over the long term The
materials used to construct different typeS-of tanks vary and the Agency, in the technical
standards promulgated in 1988, initially determined specific testing methods and
frequency based on the risk posed by those materials. The Agency concedes that coated
cathodically protected steel tanks meeting the UST regulations pose orders of magnitude '
less nsk of failure due to external corrosion than unprotected steel tanks. Nevertheless.
the fact remains that steel, if its protection is compromised, 'is subject to long-term
progressive deterioration by way of corrosion in a way that fiberglass-reinforced plastic is
not. In the preamble to the proposed technical rule. The Agency noted that corrosion was
the major cause of leaks from unprotected steel UST systems. See 52 Fed. fteg. 12666
(1987). The Agency believes that monitoring cathodic protection systems is necessary to
ensure that cathodically protected steel systems remain protected, and that they do not in
the future pose risks to human health and the environment similar to those the Agency
found in the past. In addition, the Agency currently does not have information indicating
that fiberglass tanks pose particular risks of failure over the long term or that imposing
periodic monitoring of fiberglass tanks, such as deflection monitoring, would reduce risks
to human health and the environment. Therefore* the Agency agrees with commenters
who argued that the lack of monitoring of deflection in fiberglass tanks is not a valid -
reason to eliminate or reduce the monitoring requirement on steel tanks.
23
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4. Duplication of Leak Detection Requirements
Several commenters4 indicated that when properly used or installed, inventory
control techniques and leak detection monitors provide notice of tank system failure and
effectively reduce chances for spills of any consequence. These commenters stated that
the cathodic protection monitoring requirement is redundant in light of these other
requirements.
Several commenters (ASTSWMO; Marcel Moreau Associates; NACE International;
State of Michigan, Department of State Police; Green Environmental & Corrosion! Inc.;
State of Missouri, Department of Natural Resources), however, noted that leak detection
monitoring and cathodic protection monitoring do not serve the same purpose. Leak
detection monitoring provides notice of releases and environmental damage. Cathodic
protection monitoring works as a means of leak prevention by providing notice of potential
corrosion which could lead to leaks. These commenters, therefore, disagreed that the two
systems are redundant, and argued that leak detection monitoring does not supersede the
need for cathodic protection monitoring.
One of these commenters (ASTSWMO) noted that more resources are currently
directed toward clean-up than to preventive measures. However, the commenter feels
that the Agency's approach to the problem of leaking USTs is essentially correct as it
addresses both ends of the tank problem -- using resources as needed to respond to leaks :
while developing requirements that focus on prevention.
Response ,
The Agency believes the current cathodic protection system monitoring
requirements do not duplicate the leak detection requirements. Leak detection systems are
designed to inform owners and operators when a leak in the UST system has a/ready
occurred. By contrast, cathodic protection systems are designed to prevent damage to
USTs by warning owners and operators that their UST system or piping is no longer
adequately protected and has become vulnerable to corrosion. Cathodic protection
systems and the requirements for monitoring them are designed to reduce the likelihood
that any release will occur and to prevent pollution; leak detection systems help to reduce
the likelihood that a leak from an UST system will become significant, but are not designed
to reduce the likelihood of a leak.
24
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5. Ease and Costs of Compliance
5.1 Ease of Cathodic Protection Monitoring
. One commenter (New York State Department of Environmental Conservation)
indicated that it is easy'to monitor cathodic protection systems. The commenter noted '
that once a system has been properly installed that provides access to the soil above the
tank, the major problem to be expected is low soil moisture content. This condition, can
lead to incorrect or incomplete readings. The commenter suggested that this could be
corrected by adding water to the soil and taking the reading again.
Another commenter (State of Missouri, Department of Natural Resources) noted
that the problem with the current monitoring requirement is that the specified frequency
differs from the frequency of other actions required under UST rules, this makes the
requirement difficult to remember. Another commenter (Chem Met, Ltd., P.C.) notes that
often there is a tendency to forget to monitor the cathodic protection system. The
commenter feels that this tendency will become more prevalent if the monitoring schedule
,rs extended.-._/. , • ' , ." /- . , , '••'..'
Another commenter (New York State Department of Environmental Conservation)
noted that the Tillinghast report states that many owners and installers do not understand
the technical basis for cathodic protection. The commenter responded that a lack of
• education should not be a reason for eliminating, the monitoring requirement. The
commenter proposed that more education is needed whelp people understand why tanks
•.are protected and how to determine if protection is adequate. One comme'nter (Xerxes
Corporation) notes that the Tillinghast report mentions the need for additional training for
installers and customers. . ' . . ;
- , ' v ' ' , . " - ' '< . , ' ' ","''-.''
- A commenter (Piping and Corrosion Specialties Incj states that incorrect testing
procedures could lead to inaccurate readings when the cathodic protection system is being
^monitored. The commenter worries that inaccurate readings may be obtained because the
Steel Tank Institute does hot have a technical report form which specifies the required
location of the test electrode so that it will be in a proper location to avoid direct influence
of the anodes on the test reading. . ,
5.2 Cost of Cathodic Protection Testing
One commenter (Fargo Tank Company) -noted that tank owners must ,hire a testing
agency at extra cost to test the cathodic protection system, an unnecessarily expensive
burden. , • • ' . . - • "
Several commenters (Cayuga Onondaga, Board of Cooperative Services; Owens-
Corning Fiberglass Corporation; Green Environmental & Corrosion, Inc.) disagreed and
stated that the actual costs of testing are minimal; One commenter (Cayuga Onondaga,
Board of Cooperative Services) indicated that the cost of testing is approximately, $95 per
year. This commenter indicated that commercially available hand-held test meters cost'
$150-$200. The commenter noted that the time required to test either tank or piping is
-------
less than five minutes if test leads are available, 10-15 minutes each if a test probe or wire
must be touched to the bottom of the tank. The commenter assumed that the cost for a
laborer to inspect the tanks would be $20 per.hour. The commenter thas calculated a
cost of $95 per year for annual testing of a six-tank facility.
Another commenter (Owens-Corning Fiberglass Corporation) cite.J a report-entitled
"UST System Installation and Maintenance" by Wayne B. Geyer. The report notes that
testing can be done with a simple and inexpensive vdltmeter and requires only five minutes
every three years. ' • , •
Another commenter (Green Environmental & Corrosion, Inc.) reports that her firm
tests over 300 sti-P3* tank sites per year. Her firm charges $200 per location, but has
charged as little as $150 per location for clients with multiple sites. The commenter is
aware of other firms that charge as little as $95 per location, which translates into an
annual cost of $32 to $67 per location.
Another commenter (Northeast Utilities Service Company) states that the annual •
cost of cathodic protection monitoring is between $130 and $500. The commenter
further states that in the past four years his company has experienced 27 releases, costing
a total of over $4 million, an average of $1 50,000 per release. The commenter concludes
that the cost/benefits analysis suggests that cathodic protection monitoring should be
retained in some form. Two other commenters (Piping & Corrosion Specialties Inc.;
ASTSWMO) report that the current monitoring requirement is a very inexpensive and cost-
effective policy to prevent tank leaks and the high cost of remediating those leaks.
5.3 Costs of Cathodic Protection Monitoring Systems Affects Consumer Choices
One commenter (Brown-Minneapolis Tank) states that it will cost the industry •
billions of dollars to monitor sti-P3® tanks. Furthermore, the cost of monitoring an sti-P3®
tank places this technology at an unfair disadvantage with other technologies that do not
have a monitoring requirement, some of which have higher failure rates than sti-P3* <
tanks.5
Several commenters8 indicate that when they inform their customers of the
monitoring requirement for sti-P3® tanks, the customers choose other tanks -- including
those that use experimental technologies with uriproven track records -- because they do
not want the burden of complying with the monitoring requirement. One commenter
(Highland Tank & Manufacturing Company #3) reported that in order to remain
competitive, his company is being forced to sell products without the proven cathodic
protection system, a technology that most customers would prefer to have but are
unwilling to purchase because of the monitoring requirement.
Another commenter (Highland Tank & Manufacturing Company #7) states that th«
regulations hurt sales of sti-P3c tanks because competitors have waged a marketing
campaign stressing concern about the safety of sti-P3* tanks and implying that such
concerns do not exist for the competition's tank. The commenter states that competitors
use scare tactics to dissuade consumers from buying sti-P3* tanks. Competitors
emphasize that the sti-P3* tank requires periodic monitoring and that if the monitoring is
-------
not performed and records are not kept, the owner .can be fined -$10,000 a day, These
claims put the sti-P3* tank at a competitive disadvantage.
Oneicommenter (Letter to David Ziegele from Anonymous) notes the steel tank
industry is currently under great pressure to be profitable as well as competitive. The
commenter reports that privately, many companies oppose .eliminating the monitoring
requirement for single-walled steel tanks. While some companies do not want to
, manufacture single-walled USTs for reasons'.of liability, the commenter feels that
companies will be forced to manufacture, such products in order to remain competitive
should the.monitoring requirement be rescinded. • , • ' .
_/ One commenter (Xerxes Corporation) states that,.based on experience, sti-P3*.
tanks, particularly single wall versions, are priced competitively'with other jtanks. The , .
commenter indicates that the added cost of the monitoring requirement does not make sti-
P3* tanks uncompetitive with competing brands. , '
Another commenter (State of Michigan, Department of State Police) notes that the
Til|inghast report indicates that owners are choosing aboveground tanks, this contradicts
"the Steel Tank Institute's claim that owners are-choosing other underground systems •
because they feel'that-the monitoring requirement is a nuisance. " •,'•'.-.'
Another commenter (Marcel Moreau Associates) notes that if consumers consider
monitoring to be a nuisance and choose other tanks it is simply a fact of life in a capitalist
economy that should not be used as a justification for "eliminating the monitoring
requirement. The commenter strongly expresses his'opinion, that monitoring is a standard
practice for a tank with a cathodic protection system. If a consumer want's to have a tank
with a cathodic protection system, it-is reasonable to require that the system be operated
properly. This commenter also acknowledges that monitoring the cathodic protection
.system costs money, but states that the practice is essential to the proper operation of an
sti-P3® tank. He argues that if one cannot afford to operate an sti-P3* tank in the manner
that it should be operated, one should consider using a different technology. He states
that if the Steel Tank Institute thinks that the cost of monitoring is causing the sti"P3*
tank to be viewed as a non-viable technology in today's marketplace, it is the result of the
natural workings of the free market.
, One commenter (Xerxes Corporation) feels that the fact that the monitoring
requirement is affecting buyers' choices is not a special case. The commenter implies that
every tank has characteristics which buyers like or dislike, and their choices will be
affected by those consumer tastes and the availability of other products on the market.
Another commenter (Green Environmental & Corrosion, Inc.) contends that when
considering whether to modify,the current monitoring requirement, the opinions of the •
engineering community should far outweigh that of an economically affected provider.
The commenter reports that the claims made by Steel Tank Institute are based on
economics rather than on engineering principles.
'27
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Response
The Agency agrees with commenters who stated'that cathodic protection
monitoring is easy to perform and relatively inexpensive. Problems commonly reported
with monitoring, such as incorrect readings caused by low soil moisture content, often can
be rectified by relatively simple means, such as adding water to the soil and taking the
reading again. The Agency agrees with the commenter who stated that a lack of
understanding of cathodic protection on the part of owners and installers should not be a
reason for eliminating the monitoring requirement, and, instead, better understanding is
what is needed. The Agency acknowledges the comment that the Tillinghast report
mentions the need for more training for UST installers and operators. The Agency
acknowledges the comment that incorrect testing procedures could lead to inaccurate
cathodic protection readings. However, the Agency believes that the UST regulatory
requirements for testing act to ensure that incorrect testing does not pose undue risks.
For example, the fact that monitoring must be repeated periodically reduces the risk that a
single inaccurate reading may be relied on for many years. The- comments overall support
the conclusion, also expressed in a report by S77, that the cost of,monitoring is minimal
and that it is easy.
Other commenters provided data showing that cathodic protection, monitoring is
relatively inexpensive, ranging from $95 to $200 per typical location with three USTs.
The monitoring is inexpensive relative to many other expenses involved in installing and
operating USTs. The Agency understands that a typical three-tank retail fuel marketing
facility costs over $100,000 to construct. In addition, the monitoring is inexpensive in
terms of both time and money relative to the costs to both the private and public sector of
the consequences of a leak, which could result from several causes, including insufficient
tank corrosion protection. There have been over 250,000 confirmed re/eases; sites with
only soil contamination often cost tens of thousands of dollars to address; remediation of
contaminated groundwater sites typically cost over $ 100,000. The Agency believes that
the costs of monitoring are reasonable and do not place an unnecessary financial burden
on owners and operators.
In response, to concerns that the costs of cathodic protect/on monitoring affect
consumer choices, the Agency acknowledges that this argument may be plausible, but
believes it is one of several factors that have lead to changes in the market shares for
various tank technologies over the past few years. In response to the commenters who
indicated that customers sometimes choose other technologies without proven track
records to avoid the monitoring burden, the Agency believes that all the technologies
allowed in the final technical rule (4O CFR 280.20) are protective of human health and the
environment. These technologies include corrosion protected steel, fiberglass-reinforced
plastic, steel clad with fiberglass-reinforced plastic, and. for sites meeting certain
requirements, steel without additional corrosion protection.
23
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6. Failure .to Enforce the Cathodic Protection Monitoring Requirement Is Not a
Justification to Relax the Frequency of the Requirement
'..'-'' _ ' t ''.."• - - , •
One commenter (New York State Department of Environmental Conservation) noted
that the Tillinghast report states that enforcement- of the monitoring requirement is not a
• high priority w.itfr-federal and state inspectors, the commenter argues that the current
lack of enforcement of the monitoring requirement .does,,not reduce the need for
monitoring. The commenter states that .if in the future leaks are detected from USTs
, because the tanks did not remain corrosion resistant, the'issue of compliance with the
cathodic protection monitoring requirements will become much more important
Another commenter (Marcel Moreau Associates) notes that corrosion protection
enforcement has not been a priority in many states because resources are being applied to'
more immediate problems Such as leaks/and existing contamination. The commenter has
noticed great interest iri corrosion protection arnong state regulatory personnel. The
commenter notes that he has conducted or is scheduled to conduct corrosion protection '
training for regulatory personnel in thirteen states. • • '
Another commenter (State of Michigan, Department of State Police) notes that the
Steel Tank Institute reports that since enforcement efforts-are directed at cleanup and,leak
detection, cathodic protection monitoring is not an essential activity in the UST program.
This commenter responds that states determine program priorities based on a, variety of
factors, and that these priorities are not necessarily an indication of the overall value of
cathodic projection1 monitoring. Another commenter (Xerxes Corporation) indicates that
although the cathodic protection monitoring requirement is not being enforced, it is still
considered a priority. -The commenter suggests that enforcement of the requirement will
occur after 1998, the regulatory deadline for all tanks'to be corrosion protected. ' '
6.1 Enforcement of the Monitoring Requirement Would Enhance Owners'and
Operators'Ability to Comply with the Requirement
Qne commenter (Cayuga/Onondaga Board of Cooperative Services) observed poor
compliance with the cathodic protection monitoring requirement. This commenter, with
more than eight years of experience in tank testing and installation involving nearly 100
sti-P3* tanks, specifically noted that the required cathodic protection testing data was on
file with owners and operators in only about 2-3% of the cases with which he had been
involved. Data were not available for a variety of reasons. Steel piling was inaccessible,
lacked protective cathodic coatings, or did not have anodes attached, \Some tanks had
anodes that were stillcdvered by plastic coverings on inspection following installation.
The commenter also noted that fewer than 50% of the tank installations he observed
provided test leads accessible for test metering. The commenter concludes that sinpe
there is a small number of accessible, cathodically protected piping installations, the
cathodic protection monitoring regulations, both state and federal, appear unfeasible.
29
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Response
While the Agency acknowledges that enforcement priorities may vary among
states, the extent of current enforcement activity does not determine the need for the
frequency of monitoring cathodic protection systems. The Agency believes that cathodic
protection monitoring is an important component o'f prevention activities for UST owners
and operators. Cathodic protection monitoring is important because it is a relatively '
inexpensive preventive measure owners and operators can take to ensure they do not have
equipment susceptible to external corrosion and the resulting product loss. The Agency
also notes that the UST regulations require less frequent cathodic protection monitoring
than do other federal regulations promulgated by EPA (4O CFR 264 195) and the
Department of Transportation (49 CFR 192.455 to 192.477, Appendix D) The Agency
does not believe the UST monitoring requirements are unnecessarily burdensome.
The Agency acknowledges that in many states, enforcement of the leak detection
requirements have been given priority over cathodic protection monitoring requirements
because of the earlier leak detection compliance deadlines. However, the Agency agrees
with the comment that, with the upcoming 1998 compliance deadline for corrosion
protection of all regulated USTs, emphasis will most likely shift to include more vigorous
enforcement of the cathodic protection monitoring requirements. This is because
comphance with the 1998 deadline is very important in protecting the environment and
because enforcement can be more straightforward and uniform at that time, since there
will be no question as to whether an UST must meet the requirements.
In response to the commenter who stated that since there are many tanks without '
test leads accessible for testing, the Agency notes that, while test leads make monitoring
easier, they are not necessary for testers to make the needed electrical contacts
30
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7. Miscellaneous Issues
One commenter (KCL Projects Ltd.) expressed concern that the sti-f?3*> system has
no means of protection against internal corrosion. This commenter suggested that the
Agency ask Tillinghast to' -provide data relating to/the effectiveness1 of the sti-P3* tank at
preventing leaks due to internal corrosion. -• ' ' , : .
One commenter (Fond du Lac County, Office of the County Highway Commission)
misunderstood the solicitation for comments, and argued that the Agency should not
impose stricter standards on sti-P3® tanks by requiring .that those tanks be removed and
upgraded with new cathddic protection devices. * '
One commenter (Corrosion Control Specialist, Inc.) stated that the Agency and
NACEineed to clarify that the qualifications for a corrosion engineer which are stated in 40
CFR Section 280.12 should not be interpreted too liberally. Specifically, clarification
should focus on-distinguishing between the different levels of NACE certifications.
Another commenter (AT&T) states that,the Agency needs to formalize it's position
regarding cathodic, protection testing of double wall USTs, and that the position be
included in any amendments to the cathodic-protection requirements of the UST '.
regulations. The commenter says that currently the Agency's position is that the UST
.regulations do not require testing of double wall steel USTs, but that state and local
regulatory agencies that promulgate and enforce' UST regulations may not be aware of the
Agency's position. This position was delineated in>a letter dated July 18, 1991 from
David O.'Brien of the Agency to Charles A., Frey of Highland Tank & Manufacturing
Company. The commenter states that the RCRA Hotline and OUST refer to this letteras a
statement of the Agency's position. " (
One commenter (Fiberglass Petroleum Tank & Piping Institute) states that sti-P3«
tanks dp not qualify to be sold under the Underwriters Laboratories label. The commenter
vnotes that the Steel Tank Institute alludes to compliance with the UL standard in their
advertisements because they say, "built to nationally recognized Steel Tank Institute and
Underwriters Laboratories standards." This commenter asks the Agency to recognize that
the Steel Tank Institute advertisements, despite their reference to UL. should not be
assumed to, convey approval of the sti-P3« tank by Underwriters Laboratory.
Response
, ' " . "' - • - 1 ','''"'. r , ' '. ' .- ' '
In general, the Agency acknowledges these comments but does not believe they
are directly relevant to the issues addressed by the Notice of Da.ta Availability, nor do they
provide specific data that can be used in evaluating the appropriateness of the current
cathodic protection monitoring requirement. The Agency, however, appreciates these
comments and has given them due cons/deration in its decisionmaking process.
In response to the comment regarding internal corrosion, the Agency notes thst its
current inquiry is limited to STI's request to relax the monitoring requirements, the
Tillinghast report, and the Notice of Data Availability, which all focus on external
, • '" .'....-. 31 •'•..-••.••• • . <- .. • ; :;
-------
corrosion. In any event, the Agency's information is that internal corrosion of, steel tanks
historically poses a much smaller risk of release than does external corrosion.
The comment concerning removal of sti-P3^ tanks is not relevant because cathodic
protection monitoring applies only to installed tanks: The cathodic protection requirement
has no direct relation to tank removal. , . '
The comment regarding the UST regulations, corrosion engineer qualifications, and
NACE International certification levels is not within the scope of STI's request to relax the
monitoring requirements, the Tillinghast report, or the Notice of Data Availability. In any
event, the Agency is reviewing these subjects in a separate activity and acknowledges this
comment.
The Agency acknowledges the comment regarding cathodic protection monitoring
of double wall cathodically protected steel USTs. However, the Agency's Notice of Data
Availability spoke to single wall cathodically protected tanks, and the Agency be/ievls it is
this type of tank which is most crucial to monitor for cathodic protection.
In response to the comment about the compliance of sti-P3*> tanks with
Underwriters Laboratories (UL) standards and about STI advertisements, the Agency notes
that this comment is not within the scope of the current discussion. Instead, this is a
matter more appropriately pursued with STI and/or with UL. ;
32
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ENDNOTES ,
1. John W. Kennedy Company, Inc. #1; JEMKO' Petroleum Equipment* Inc.;,Oil Equipment
Sales, Inc.; Northeast Mechanical Corporation; EnviroReps, Inc.; Advanced Pollution ,
Control; Parker & Associates, Inc.; Fedco Tank and Equipment, Inc.; John W. Kennedy
'Company, Inc: #2; Pet-Chem. Equipment Corp.; Gould Equipment CompanyrWhitelock and
Woerth, Inc., Francis Smith & Sons, Inc.; J.M.A. Associates, Inc.; Engineered Equipment
Sales Inc.; Quality Petroleum Systems, Inc.; Hirri Service Company; Professional Petroleum;
Service Company; TJ Equipment Company;-James B. Phillips Company, Inc.; Trombold .
Equipment Company; Young Equipment Division; D.T. O'Connor, Inc.; Meter & Tank
; Equipment Company, Inc. #1; Meter & Tank Equipment Company, Inc. #2; Meter & Tank
Equipment Company, Inc. #3; Samuel K. Spigler Company, Inc.; Highland Tank &
Manufacturing Company #9; Sammie Huff Contractors, Inc., Gilarco Sales & Service; Ten
Hoeve Brothers,.Inc. #2; Ten Hoeve Brothers, Inc. #3; Jon El, Inc., Mechanical Equipment
Sales; NECO Equipment Company; Allan U. Bevier, Inc.; Tate Instrumentation & Controls
2.( -These commenters misinterpreted the total failure rate provided for the 591 tanks in
the Geyer Report. The actual failure rate cited in the Geyer Report is 10%.
3. Highland Tank & Manufacturing Company #1; Highland Tank & Manufacturing
Company #2; Luther P. Miller, Inc.; TooMSI-Scoot: A Division of Best Oil Inc.; Boulder Oil
Company; Dean Fowler Oil Company; Lou Korchak Oil Company, Inc.; John W. Kennedy
Company, Inc. #1; Emmart Oil Company; Enercon Services, Inc.; Highland Tank &
Manufacturing Company #3; Midstate Fuel Storage Systems; Interface Services, Inc. #1;
Alaskan Oil; Clemett & Company; Interface Services, Incl #2; JEMKO Petroleum
Equipment; Inc.; Earl "Jerry" Galvin Manufacturers Representative; Environmental &
Energy. Systems Company #1; Carlucci Construction Company, Inc.; Environmental &
Energy Systems Company #2; Oil,Equipment Sales, Inc.; Fedco Manufacturing ••
Corporation; JABE Construction &. Equipment Inc.; Barkman Oil Company Inc.;
Environmental & Energy Systems Company #3; Miller's Petroleum Systems, Inc.; Tiger
Fuel Company; H.J. Tanner, Inc.; Northeast Mechanical Corporation;'Glider Oil Company;
EnviroReps, Inc.; HOB8S Inc. #1; Advanced Pollution Control; HOBBS Inc. #2; Parker &
Associates, Inc.; Fedco Petroleum Installations, Inc.; Kelley Omega, Inc.; Fedco Tank and
Equipment, Inc.; Center Point Tank Services, Inc.; C & S Contractors & Equipment, Inc.;
Mon Valley Petroleum Company; Northrup Supply Corp.; Environmental & Energy Systems
Company #4; J & J Marts, Inc., Mountaineer Mart; Gary Dyer Excavating Company, Inc.;
Purvis,Brothers, Inc.; Everybody's Oil Corporation; Alaskan Oil Inc.; International
Association of Tank Testing Professionals; Coldiron Fuel, Inc.; Griffith Oil Company; C.
Arlo Cummins; John W. Kennedy Company, Inc. #2; Bettiol Fuel Service, Inc.; Ravenna Oil
Company; Pet-Chem Equipment Corp.; leake Oil Company; Cuyahoga Landmark Petroleum
Services; Varouh Oil, Inc.; The Lyden Company; Cross Oil Corporation; Highland Tank &
Manufacturing Company f4; Gould Equipment Company; Beaver Petroleum Co. Inc.; M&M
Oil Company, Inc.; The Coen Company; Petroleum Equipment Services, Inc.; James A.
Grogey; Worth & Company, Inc.; A. Graziani & Company. Inc.; Highland Tank &
Manufacturing Company *5; Whitelock and Woerth, Inc.; McKenzie Group. Inc.; Voegele
Mechanical, Inc.; Francis Smith & Sons, Inc.; J.M.A. Associates. Inc.; Engineered
Equipment Sales Inc.; Joseph Stong, Inc.; Quality Petroleum Systems. Inc.; Beck
Suppliers, Inc; Lechmanik. Inc.; Ward's Pump and Tank; Edward J. Meloney. Inc.; Valley
• . •• '. "..'»• • ' v' ' '• / ,.-••'.-•
'• ' ' ' -..-,"' 33 - •...••••-'.-•,
-------
Equipment Company, Inc. #1; Grace Oil Company; Republic Oil Company, Inc.; Valley
Equipment Company, Inc.. #2; Numb Remodeling & Equipment; Jack Hirsch; Hirri Service
Company; Black Equipment, Inc.; Professional Petroleum Service Company; TJ Equipment
Company; James B. Phillips Company,-Inc.; United Environmental Group Inc.; Fedco Tank
& Equipment, Inc.; Cernak Tank Company, Inc.; United Marketing, United Refining
Company of Pennsylvania; Petro Tech Electronics Inc.; Trombold Equipment Company;
G.E. Sell, Inc.; Steven J. Tornabine; Crawford Fuel & Oil; Holmes Oil Company; Young
Equipment Division; Marshall Farms, inc.; M&E Anderson Equipment & Testing; Laurel
Valley Oil Company; E.E. Wine, Inc.; Rice Christ, Inc. #1; Rice Christ, Inc. #2; Rice'Christ,
Inc. #3; Eastern Petroleum Services, Inc.; Ullman Oil, Inc.; Carl Mundy Contractors #1;
James Nichols; Tri-State Petroleum Corporation #1; Petroleum Services, Inc.; Ten Hoeve
Brothers, Inc. #1; Carl Mundy Contractors ff2; Kay Bibih; Tess Bechtold; D.T. O'Connor,
Inc.; Penzoil Products Company; Carl Mundy Contractors #3; Joe DeFazio Oil Company;
Childers Oil Company; J.H. Crosier Company; Bell Petroleum Ltd., Aviation Products
Division #1; Fred's Plumbing and Heating #1; Fred's Plumbing and Heating #2; Sammy L.
Throlup; Benit Fuel Sales & Service Inc. #1; Highland Tank & Manufacturing Company #6;
Benit Fuel Sales & Service Inc. #2; Bell Petroleum Ltd., Aviation Products Division #2;
Highland Tank & Manufacturing Company #7; Herman Goldner Company, Inc.; A.C. & T.
Company, Inc.; Caledonia Oil Company #1; Caledonia Oil Company #2; Mountain,State Bit
Service, Inc.; SICO Company; Caledonia Oil Company #3; Meter & Tank Equipment
Company, Inc. #1; Meter & Tank Equipment Company, Inc. #2; Meter & Tank Equipment
Company, Inc. #3; Samuel K. Spigler Company, Inc.; Highland Tank & Manufacturing
Company #8; Highland Tank & Manufacturing Company #9; Alliance Oil Service Company;
Cortland Pump & Equipment Company; Bedford Valley Petroleum Corporation; Coastal
Pump & Tank, Inc.; First State Petroleum Services, Inc. #1; Willison Oij, Inc.; Petroleum
Industry Consultants, Inc.; Tri-State Petroleum Corporation #2; Sammie Huff Contractors,
Inc., Gilarco Sales & Service; Ten Hoeve Brothers, Inc. #2; Ten Hoeve Brothers, Inc. #3;
Jon El, Inc., Mechanical Equipment Sales; Lane & Clark Mechanical Contractors, Inc.; Craig
K. William; Joseph Goffrey; Oil Equipment Sales & Service Company, Inc. (OESSCQ);
APCON Environmental Services, Inc.; Franklin Oil Company, Inc. #1; Baird Petroleum
Equipment; Corporation; Harris Oil Company^ Inc.; Emmart Oil; Highland Tank &
Manufacturing Company #11; James Islintu; R.L. Smiltz Oil Company, Inc.; Albright Oil,
Inc.; Howard Gasoline & Oil Company; Shelving Installation Service, Inc.; First State
Petroleum Services, Inc. #2; K & T Pump & Tank, Inc.; DePue Oil Company; NECO
Equipment Company; Franklin Oil Company. Inc. #2; Allan U. Bevier, Inc.; Highland Tank &
Manufacturing Company #12; Charles A. Frey; Oil Repair & Installation Company, Inc.;
Delmarva Tank Specialists, Inc.; Smiles Are For Free - Everything Else is C.O.D.; Highland
Tank & Manufacturing Company #13; Richard D. Galli; Goode Omega, Inc.; Tate
Instrumentation & Controls
4. Fargo Tank Company; Highland Tank & Manufacturing Company #1; Luther P. Miller,
Inc.; Toot-N-Scoot: A Division of Best Oil Inc.; Boulder Oil Company; Dean Fowler Oil
Company; Lou Korchak Oil Company. Inc.; John W. Kennedy Company, Inc. #1; Emmart
Oil Company; Enercon Services, Inc.; Midstate Fuel Storage Systems; Interface Services,
Inc. #1; Alaskan Oil; Clemett & Company; Interface Services, Inc. #2; JEMKO Petroleum
Equipment. Inc.; Earl "Jerry" Galvin Manufacturers Representative; Environmental &
Energy Systems Company #1; Carlucci Construction Company, Inc.; Environmental &
Energy Systems Company #2; Oil Equipment Sales. Inc.; Fedco Manufacturing
34
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Corporation; JABE Construction & Equipment Inc.; Barkman Oil Company Inc.;
Environmental & Energy Systems Company #3; Miller's Petroleum Systems, Inc.; Tiger -
Fuel Company; H.J. Tanner, Inc.; Northeast Mechanical Corporation; Glider Oil Company;
EnviroReps, Inc.; HOBBS Inc. #1; Advanced Pollution Control; HOBBS Inc. #2; Parker &
Associates, Inc.;.Fedco Petroleum Installations, Inc.; Kelley Omega, Inc.; Fedco Tank and
Equipment, inc.s; Center Point Tank Services, Inc.; C &'S Contractors & Equipment, Inc.;
Mon Valley Petroleum Company; Northrup Supply Corp.; Environmental .& Energy Systems
Company #4; J & J Marts, Inc. Mountaineer Mart; Gary Dyer Excavating Company, Inc.;
Purvis Brothers, inc.; Everybody's Oil Corporation; Alaskan Oil Inc.; Coldiron Fuel, Inc.; ' •
Griffith Oil Company; C. Arlo Cummins; John W. Kennedy Company, Inc. #2; Bettiol Fuel
Service, Inc.; Ravenna Oil Company; Pet-Chem Equipment Corp.; Leake Oil Company;
Cuyahoga Landmark Petroleum Services; Varouh Oil, Inc.; The Lyden Company; Gross-Oil
Corporation; Highland Tank & Manufacturing Company #4; Gould Equipment Company;
.Beaver Petroleum Co. Inc.; M&M Oil Company, Inc.; The Coen Company; Petroleum
Equipment Services, Inc.; James A. Grogey; Worth & Company, Inc.; A. Graziani &
Company, Inc.; Highland tank & Manufacturing Company #5; Whitelock and Woerth, Inc.;
McKenzie Group, Inc.; Voegele Mechanical,, Inc.; Francis Smith & Sons, Inc.; J.M.A.
Associates', Inc.; Joseph Stong, Inc.; Quality Petroleum Systems, .Inc.; Beck Suppliers, Inc;
Lechmanik, Inc.; Ward's Pump and Tank; Edward J. Meloney, Inc.; Valley Equipment
Company, Inc. #1; Grace Oil Company; Republic Oil Company, Inc.; Valley Equipment .
Company, Inc. #2; Humb Remodeling & Equipment; Jack Hirsch; Hirri Service Company;
Black Equipment, Inc.; Professional Petroleum Service Compa.iy; TJ Equipment Company;
United Environmental Group Inc.; Cernak Tank Company, Inc.; United Marketing, United
Refining Company of Pennsylvania; Petro Tech Electronics Inc.; Trombold Equipment
Company; G.E. Sell, Inc.; Steven J. Tornabine; Crawford Fuel & Oil; Holmes Oil Company;
Young Equipment Division; Marshall Farms, Inc.; M&E Anderson Equipment & Testing-
Laurel Valley Oil Company; E.E, Wine, Inc:; Rice Christ, Inc. #1; Rice Christ, Inc. #2; Rice
Christ, Inc. #3; Eastern Petroleum Services, Inc.; Ullman Oil, Inc.; Carl Mundy Contractors
#1; James Nichols; Tri-State Petroleum Corporation #1; Petroleum Services, Inc.; Ten
Hoeve Brothers, Inc. #1; Carl Mundy Contractors #2; Kay Bibih; Tess Bechtold; D.T.
O'Connor, Inc.; Penzoil Products Company; Carl MundyXontractors #3; Joe DeFazio Oil
Company; Childers Oil Company; J:H. Crosier Company; Highland Tank & Manufacturing
Company #6; Benit Fuel Sales & Service Inc. #2; Bell Petroleum Ltd., Aviation Products
Division #2; Highland Tank & Manufacturing Company #7; Herman Goldner Company,
Inc.; A.C. & T. Company, Inc.; Caledonia Oil Company #1; Caledonia Oil Company #2;
Mountain State Bit Service, Inc.; SICO Company; Caledonia Oil Company #3; Meter &
Tank Equipment Company, Inc. #1; Meter & Tank Equipment Company, Inc. '#2; Meter &
Tank Equipment Company, Inc. #3; Samuel K. Spigler Company, Inc.; Highland Tank &
Manufacturing Company #9; Alliance Oil Service Company; Cortland Pump & Equipment
Company; Bedford Valley Petroleum Corporation; Coastal Pump & Tank, Inc.; First State
Petroleum Services, Inc. #1; Willison Oil, Inc.; Petroleum Industry Consultants, Inc.;
Tri-State Petroleum Corporation #2; Sammie Huff Contractors, Inc. Gilarco Sales &
Service; Ten Hoeve Brothers, Inc. #2: Ten Hoeve Brothers, Inc. #3; Jon El, Inc.,
Mechanical Equipment Sales; Lane & Clark Mechanical Contractors, Inc.; Craig K. William;
Joseph Geffrey; Oil Equipment Sales & Service Company, Inc. (OESSCO); APCON
Environmental Services. Inc.; Franklin Oil Company, Inc. #1; Harris Oil Company, Inc.; ,
Emmart Oil; Highland Tank & Manufacturing Company #.11; R.L. Smiltz Oil Company, Inc.;
Albright Oil, Inc.; Howard Gasoline & Oil Company; Shelving Installation Service, Inc.; First
35
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State Petroleum Services
Equipment Comp.ny.-IS,
0.1 Repair & Installation Company Inc De'marva Tank
Free - Everything Else is C 0 •
Gal,i; Goode Omega. ,nc,
Oil C°mP-v: I*=CQ
• ,' C"' Charles *'
ists. Inc.; Soi.les Are For
"* RiChard
.r
Inc.; John W, Kennedy Company lnc #2 Pet
Manufacturing Company ^Gou'lc^ ^ Equtpmen "
Highland Tank & Manufacturing Company ff 5'
Associates. Inc.; Engineered Eaui
Service Company; ^nSSJ^S
James B. Phillips Companv Inc • Trnmhnw
Young Equipment DivisTn Nen H! °vT B
Petroleum Ltd., Aviation Products Division #1
Plumbing and Heating #2; Sammy L Th°olun
Tank & Manufacturing Company #7
Tank Equipment Company, inc #
Sp.gler Company. Inc.; Highland T
Contractors, Inc., Gila co Sales & prv>
Brothers. Inc. *3 Jon El ,nc Mechan r!f P "
Corporation; James .shnuNECO Ecu?!' t"^'^
Frey; Tate Instrumentation & Controls
•
dC° Tank and
,
•^ HiQhland Tank &
Petroleum Co' ^-'
Sons' lnc-' J'M-A-
'-, Hirri
Company;
™ & °il;
' 'nc'; Be"
3nd Heating #1; Fred's
En, » r ^'^ lnc"#1' Highland
S Company, Inc. #1; Meter &
ComPan*< lnc- #3; -Samuel K.
Company #9; Sammie Huff
' lnc- #2; Ten Hoev«
'^ Petr°'eum E^™"
U' 8ev'er' lnc'; Charl^ A.
*
P
36
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RECOGNIZED STANDARDS FOR CATHODIC PROTECTION MONITORING
Organization
NACE International, formerly
National Association of
Corrosion Engineers
Canadian Council of Ministers
of the Environment (CCME)
National Standard of Canada
Petroleum Equipment
institute (PEI)
American Petroleum Institute
(API)
National Fire Protection
Association (NFPA)
Uniform Fire Code (UFC)
Citation
RP-02-85 (1985)'
§10.2, 10.3 ;
CCME EPC-LST-61 E (1 993)
§4.9.2(4), 6.4.1(2)
ULC CAN4-S603.1-M85
(1985)
§A1.4,B3. 12.3.1, 83. 12.4.1
PEI/RP 100-94 (1994)
§10.13, 12.2
API RP #1632 (1987)
§3.6.6
NFPA 30 (1993)
$2-4.3
1991
§79.603
Criteria
-0.85V
-0.85V
-0.85V
-0.85V
-0.85V
Initial Monitoring
When the system is
energized
After installation
After backfilling and
before commencing
paving
Before placing UST
system in service. If
system fails, facility may
operate, but test should
be repeated in 90 days
and repaired if needed.
6 to 1 2 weeks after
installation and one year
thereafter:
Monitoring Interval
Annually
Annually
After the first 1 2 months of installation and
every two years thereafter
• . > . t • ' ' • ' •
Not specified
j .- - " '•'•.,. . ^
Every 5 years. If underground work is
performed at the site, 6 to 12 weeks after
completion and one year thereafter before
extending interval to 5 years.
A cathodic protection system should be engineered, installed and
maintained in accordance with recognized standards of design such as: API
1632, ULC-S603.1 M, Steel Tank Institute Standard No. sti-P3, NACE RP-
01-69 (1983), NACE RP-02-85 (1985)
At installation
Not less than once every five years
VJ
§
T
*.
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RECOGNIZED STANDARDS FOR CATHODIC PROTECTION MONITORING (cent.)
Organization
Citation
Criteria
Initial Monitoring
Monitoring Interval
Department of Transportation
(DOT)
49 CFR
§192.455 to §192.477.
Appendix D
-0.85V
For pipelines installed after
July 31. 1971, cathodic
protection system must be
installed and placed in
operation within one year
of construction. For
pipelines installed prior to
August 1, 1971. each
area that has an effective
external coating must be
cathodically protected.
Cathodic protection for each pipeline must be
tested once a year at intervals not exceeding
15 months. Each rectifier must be inspected
six times a year at intervals not exceeding 2 5
months. For pipelines transporting corrosive
gas, each means of monitoring internal
corrosion must be checked twice yearly at
intervals not exceeding 7.5 months. Each
reverse current switch, diode and interference
bond whose failure would jeopardize protection
must be checked six times a year at intervals
not exceeding 2.5 months.
Environmental Protection
Agency
40 CFR
§264.195
-0.85V
For tanks storing or
treating hazardous
wastes, inspection of the
cathodic protection
system must be performed
within six months of
installation
The cathodic protection system must be
inspected annually after the initial inspection.
All sources of impressed current must be
inspected and/or tested at (east every 60 days.
Guidelines for inspections may be found in
NACE RP-02-85 and AP11632. Results of
inspections must be kept in facility operating
record.
Environmental Protection
Agency
40 CFR
§280.31
-0.85V
For all steel UST systems
with corrosion protection,
inspection of the cathodic
protection system must be
performed within six
months of installation by a
qualified cathodic
protection tester
The cathodic protection system must be
inspected every three years after the initial
inspection. UST systems with impressed
current cathodic protection systems must be
inspected every 60 days to ensure that the
equipment is running property. Guidelines for
inspections may be found in NACE RP-02-85
and AP11632. Records must be maintained of
the last two inspections for cathodic protection
systems, and the last three inspections for
impressed current cathodic protection systems.
1. Work is underway on a revision to this Recommended Practice, which when completed may not specify a monitoring interval. Anticipated date is
I *7«7O»
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