United States
Environmental Protection
Agency
Office of
Underground Storage Tanks
Washington, D.C. 20460
&EPA
EPA/530-SW-8S-023
August 1986
OSWER DIR.9650.1
The Interim Prohibition:
Guidance for Design and
Installation of Underground
Storage Tanks ^
^^ 10,;- s.; r /
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OSWER DIR.9650.1
DISCLAIMER
The mention of specific trade names is for informational purposes only
and is not intended as an endorsement of a particular system.
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OSWER DIR.9650.1
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY 1
INTRODUCTION 1
Background 1
Purpose of This Document 3
Organization of This Document 3
Use of This Document 4
Compliance with State and Local Law 4
The Interim Prohibition 5
1.0 DESIGNS FOR COMPLIANCE WITH THE INTERIM PROHIBITION 5
1.1 Corrosion Protection 5
1.1.1 Cathodic Protection 6
1.1.2 Noncorrosive Materials of Construction 6
1.1.3 Noncorrosive Cladding 6
1.2 Structural Integrity 6
1.3 Installation of "Used" Tanks 7
1.4 Secondary Containment 7
2.0 THE PROTECTION OF UNDERGROUND TANKS FROM CORROSION 7
2.1 Causes of Underground Tank Corrosion 8
2.1.1 Galvanic Corrosion 8
2.1.2 Stray Current Corrosion 11
2.1.3 Internal Corrosion 11
2.2 Types of Corrosion Protection 11
2.2.1 Cathodic Protection 11
A. Sacrificial Anode Systems 11
B. Impressed Current Protection Systems 14
C. Monitoring System Performance 20
2.2.2 Noncorrosive Materials of Construction 22
2.2.3 Steel Clad with Noncorrosive Materials 22
2.2.4 The Exemption from Corrosion Protection Requirements 23
2.2.5 Secondary Containment Systems 24
A. Double-Walled Tanks 24
B. Pit Lining Systems 25
(1) Low Permeability Constructed Barriers 28
(2) Synthetic (Polymeric) Membrane Liners 28
(3) Vaults 29
(4) Secondary Containment of Piping 29
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OSWER DIR.9650.1
TABLE OF CONTENTS
(continued)
Page
3.0 THE PROTECTION OF UNDERGROUND TANKS FROM
STRUCTURAL FAILURE 29
3.1 Causes of Underground Tank Structural Failure 29
3.2 Installation Considerations 31
3.2.1 Excavation 32
3.2.2 Tank Bedding 32
3.2.3 Tank Anchoring 34
3.2.4 Piping 34
3.2.5 Other Attachments 34
3.3 Tank Design Considerations 34
4.0 THE COMPATIBILITY OF UNDERGROUND TANKS WITH
SUBSTANCES STORED 38
4.1 Compatibility Considerations 38
4.2 FRP/Alcohol Compatibility 38
4.3 Characteristics of Tank Liner and Construction Materials 40
4.3.1 pH Extremes 40
4.3.2 Chlorides and Fluorides 40
4.3.3 Oxidation 41
4.3.4 Solvent Action 41
4.4 Lining Tanks 41
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OSWER DIR.9650.1
TABLE OF CONTENTS
(continued)
LIST OF FIGURES
Page
2.0 THE PROTECTION OF UNDERGROUND TANKS FROM CORROSION
2-1 Galvanic Cell 9
2-2 Galvanic Corrosion on an Underground Tank System 9
2-3 Galvanic Corrosion Caused by Differences in Soil Aeration and
Moisture 9
2-4 Galvanic Corrosion Between a New Tank and an Old Tank 10
2-5 Corrosion Pitting Action 10
2-6 Stray Current Corrosion 13
2-7 Cathodic Protection by the Sacrificial Anode Method 15
2-8 Pipe Corrosion 16
2-9 Underground Tank and Piping System 17
2-10 Pre-Engineered Sacrificial Anode System 18
2-11 Impressed Current Cathodic Protection System 19
2-12 Structure to Soil Measurement System 21
2-13 Double-Walled Tank Configuration 26
2-14 Secondary Containment Using Liner Technology 27
2-15 Secondary Containment Vault 30
3.0 THE PROTECTION OF UNDERGROUND TANKS FROM
STRUCTURAL FAILURE 33
3-1 Excavation 33
3-2 Bedding 35
3-3 Tank Anchoring Concept 35
3-4 Tank Piping Details - Suction System 35
3-5 Normal Tank Loads 36
3-6 Tank Load Schematic 37
iii
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TABLE OF CONTENTS
(continued)
LIST OF TABLES
Page
2.0 THE PROTECTION OF UNDERGROUND TANKS FROM CORROSION
2-1 Galvanic or Electromotive Force Series 12
4.0 THE COMPATIBILITY OF UNDERGROUND TANKS WITH
SUBSTANCES STORED
4.1 Compatibility Chart: Structural Materials vs. Chemicals 39
APPENDICES
A Subtitle I, Regulation of Underground Storage Tanks, (1982) A-1
B Interpretive Rule B-1
C State Underground Storage Contacts C-1
D Recommended Publications D-1
E Regulated Substances E-1
F ASTMG57-78 F-1
iv
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OSWER DIR.9650.1
EXECUTIVE SUMMARY
The Hazardous and Solid Waste Amendments of 1984 (Public Law 98-616) were signed by the
President on November 8, 1984. One part of this law requires EPA to establish a national regulatory
program for the control of new and existing underground tanks and their associated piping that are
used to store liquid petroleum products or other chemicals defined as "hazardous substances." Under
the new law, an "Interim Prohibition" on the installation of underground tanks went into effect on May
7, 1985 that will continue until EPA promulgates permanent new tank performance standards. The
Interim Prohibition is intended to prevent future leaks from newly installed underground tanks caused
by three types of problems: corrosion, structural failure, and incompatibility of the contents with tank
liner and construction materials.
Members of affected industries and other interested parties have posed many questions to EPA
about how new underground tanks can meet the requirements of the Interim Prohibition. This guidance
document was prepared to answer many of these questions and to aid owners and installers of new
tanks in their efforts to comply with this Federal law. The document provides information on the types
of technologies and practices that can be used to satisfy the requirements of the Interim Prohibition.
Of course, owners and installers of new tanks must continue to comply with all State and local
underground tank regulations. The introduction to this document contains a section on designs which
EPA believes will comply with the Interim Prohibition.
The organization of this document parallels the requirements of the Interim Prohibition. Chapter
1 briefly describes specific features which comply with the Interim Prohibition. Chapter 2 addresses
underground tank corrosion, including why metal tanks corrode and how to protect against corrosion.
It includes discussions on cathodic protection, corrosion-resistant materials of construction and coatings,
the exemption from the Interim Prohibition's corrosion protection requirement, and secondary con-
tainment systems. Chapter 3 discusses the causes of underground tank structural failure and the
primary means of prevention, namely, proper tank installation practices. Chapter 4 provides guidance
about the compatibility of tank liner and construction materials with the substances being stored.
This guidance also includes several appendices. Appendix A is the complete text of the federal
law pertaining to the regulation of underground storage tanks. Appendix C provides the names and
addresses of State personnel who can be contacted concerning the status of applicable State tank
regulations. Appendix D contains a list of publications that cover in greater detail the topics introduced
by this manual. Appendix E lists all regulated "hazardous substances," as defined by Section 101(14)
of the Superfund act. These substances are included in the definition of "regulated substance" in
Section 9001(2) of the statute, in establishing which tanks are subject to the requirements of the law.
This guidance document is the only technical information EPA intends to issue on corrosion, struc-
tural failure, and compatibility, as they relate to the Interim Prohibition. An "interpretive rule" on the
Interim Prohibition, published in the Federal Register on June 4, 1986. should be used in conjunction
with this manual. This Interpretive Rule is included as Appendix B in this manual.
INTRODUCTION
Background
The Hazardous and Solid Waste Amendments of 1984 (Public Law 98-616) were signed by the
President on November 8, 1984. These amendments to the Resource Conservation and Recovery
Act (RCRA) add a new Subtitle I entitled, "Regulation of Underground Storage Tanks.1 Part of these
1
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OSWER DIR.9650.1
amendments require EPA to develop and establish a national regulatory program for the control of
new and existing underground storage tanks containing "regulated substances" as defined by this
Act. The scope of this new program is broad and applies to tanks and combinations of tanks with
10 percent or more of their volume underground, including the volume of underground piping, that
are used to store petroleum products or other liquid materials defined as hazardous substances under
Section 101(14) of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA, commonly known as Superfund). The following tanks are excluded from the Interim
Prohibition:
• Farm or residential tanks of 1,100 gallons or less capacity used for storing motor fuel for non-
commercial purposes;
• Tanks used for storing heating oil for consumptive use on the premises where stored;
• Septic tanks;
• Flow-through process tanks; and
• Tanks above floor level but still underground.
Subtitle I does not regulate underground tanks containing hazardous waste. These tanks are
regulated under Subtitle C of RCRA.
The U.S. Congress enacted Subtitle I out of concern for the risks that leaking underground tanks
and piping pose to the nation's groundwater resources. Tank leaks can pose significant threats to
public health and the environment.
Underground tank systems leak for several reasons. Corrosion, both external and internal, is one
of the most common causes of leaks. Structural failure, primarily from improper installation, can also
cause leaks. In addition, contents that are incompatible with a tank's liner and/or construction materials
may induce leakage.
Subtitle I mandates a comprehensive program to address the tank leakage problem. Among the
statute's provisions is the requirement that by May 8,1986, underground tank owners notify designated
State or local agencies of their tanks' existence. Under the law, EPA must also develop regulations
for underground tanks addressing leak detection, corrective action, closure, recordkeeping and report-
ing, and new tank performance standards. Federal inspection and enforcement of tank regulations
are also covered in Subtitle I.
In addition to these general mandates, the statute specifically establishes that an underground
tank cannot be installed, or removed and reinstalled at the same or a different location, unless certain
minimum requirements are met. These minimum requirements, known as the Interim Prohibition
(Section 9003(g)), went into effect on May 7, 1985. They apply to all new tanks containing regulated
substances until EPA establishes permanent new tank performance standards through regulation.
In summary, the Interim Prohibition requires that no underground storage tank may be installed
after May 7, 1985 unless it:
1The full text of Subtitle I can be found in Appendix A of this document.
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OSWER DIR.9650.1
(1) Will prevent releases from corrosion for the operational life of the tank;
(2) Will prevent releases from structural failure for the operational life of the tank; and
(3) Is compatible with the product to be stored.
In its interpretive rule, EPA has interpreted the term "operational life" of a tank to be "the time
during which the tank stores regulated substances." Also, "tank" is defined to include the attached
piping and fittings.
The Interim Prohibition also has a limited exemption stating that a new tank does not have to
be protected from corrosion if it is installed in a certain soil environment (as determined by a test
specified in the statute or a more stringent standard promulgated by the EPA Administrator by rule).
The statute provides for a maximum penalty of $10,000 per tank for each day the Interim Prohibition
is violated.
Purpose of this Document
Since the 1984 RCRA Amendments became effective, people in the regulated community and
other interested members of the public have posed numerous questions to EPA about how new tanks
can meet the requirements of the Interim Prohibition. The Agency has prepared this guidance docu-
ment to provide needed information concerning the types of technologies and practices that are cur-
rently available and are used to prevent releases due to corrosion, structural failure, or incompatibil-
ity. Although this document does not provide a detailed description of every technical option available
for preventing releases from underground tanks, it is intended to give tank purchasers and installers
enough information to foster sound technical decisions and compliance with the Interim Prohibition.
Failure to discuss a particular technology or method in this guidance document should not be con-
sidered a judgement by EPA that such technology or method is not acceptable under the Interim
Prohibition.
This guidance document also provides important background information about several problem
areas associated with improper tank design and installation practices that the Interim Prohibition seeks
to control. It discusses the major causes of tank leakage and some of the factors that must be prop-
erly managed to assure its prevention in new tank systems.
Organization of this Document
Each of the chapters of this guidance document focuses on one of the three major requirements
of the Interim Prohibition. Accordingly, these chapters discuss the following topics:
• Chapter 1 briefly describes specific design features which can be used to comply with the Interim
Prohibition.
• Chapter 2 addresses the corrosion of underground tanks. It provides background information
on how and why tank systems corrode. The various technologies that can be used to prevent
corrosion are presented, including descriptions of how they work and their limitations. The limited
exemption from the statute's corrosion requirement for high soil resistivity is discussed. Secon-
dary containment is briefly described as another means, besides corrosion protection, for
preventing leaks into the environment.
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OSWER DIR.9650.1
• Chapter 3 considers structural failure, from causes other than corrosion. It provides background
information on the causes of structural failure. Prevention of structural failure, primarily through
proper installation of a tank system, is described.
• Chapter 4 examines the compatibility of the product being stored in a tank with tank liner and/or
construction material. It provides background information on the problems associated with com-
patibility and discusses the consequences of storing a substance in an incompatible tank,
methods for ensuring compatibility, examples of incompatible combinations, and the limitations
of existing information and test procedures used to establish compatibility.
Several appendices are included in this guidance document to provide additional information that
may be useful to someone considering installing an underground storage tank system:
• Appendix A provides a copy of the full text of Subtitle I of the Resource Conservation and
Recovery Act. Subtitle I includes all the new law's requirements concerning the regulation of
underground storage tanks.
• Appendix B contains EPA's Interpretive Rule.
• Appendix C lists State contact personnel who can provide information on State underground
storage tank regulations.
• Appendix D provides a list of recommended publications that can be used to obtain more detailed
guidance on subjects addressed by the Interim Prohibition.
• Appendix E provides a list of all the chemicals considered "hazardous substances" under Super-
fund section 101(14).
• Appendix F provides a description of the Wenner method of soil resistivity measurement, the
test that will determine whether the exemption from corrosion protection that is allowed by the
statute is applicable.
Use of this Document
We recommend that the user of this guidance document consider the material in all of the chapters
because each of the requirements of the Interim Prohibition must be met to prevent leaks in newly
installed tanks. If it is still unclear after reading this manual whether a particular approach is adequate
to prevent leakage, EPA suggests that readers use the technical information reference list in Appen-
dix C or call EPA. For additional technical information or clarification concerning the Interim Prohibi-
tion, the reader may call the EPA hotline at (800) 424-9346.
Compliance with State and Local Law
The user of this manual is cautioned to consider carefully requirements concerning the design
and installation of new tanks that may apply under State and/or local law. Such requirements must
be met if they are consistent with or are more stringent than the Interim Prohibition. In other words,
compliance with the Interim Prohibition may not, in some instances, be adequate compliance for pur-
poses of State or local law.
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OSWER DIR.9650.1
The Interim Prohibition
For the reader's reference and understanding, the text of the Federal Interim Prohibition govern-
ing the design and installation of new tanks (Section 9003(g) of RCRA, as amended) follows:
Section 9003(g) of RCRA, as amended
"INTERIM PROHIBITION—(1) Until the effective date of the standards promulgated by the Administrator
under subsection (e) and after one hundred and eighty days after the date of enactment of the Hazar-
dous and Solid Waste Amendments of 1984, no person may install an underground storage tank for
the purpose of storing regulated substances unless such tank (whether of single or double wall
construction)—
(A) Will prevent releases due to corrosion or structural failure for the operational life of the tank;
(B) Is cathodically protected against corrosion, constructed of noncorrosive material, steel clad
with a noncorrosive material, or designed in a manner to prevent the release or threatened
release of any stored substance; and
(C) The material used in the construction or lining of the tank is compatible with the substance
to be stored.
(2) Notwithstanding paragraph (1), if soil tests conducted in accordance with ASTM Stan-
dard G57-78, or another standard approved by the Administrator, show that soil resistiv-
ity in an installation location is 12,000 ohm/cm or more (unless a more stringent standard
is prescribed by the Administrator by rule), a storage tank without corrosion protection
may be installed in that location during the period referred to in paragraph (1)."
1. DESIGNS FOR COMPLIANCE WITH THE INTERIM PROHIBITION
This document describes a variety of approaches to designing and installing underground storage
tanks under the Interim Prohibition. The purpose of this section is to identify some specific designs
or features which EPA believes will comply with the provisions of the Interim Prohibition.
1.1 Corrosion Protection
The Interim Prohibition provides the following three specific alternatives for preventing corrosion:
(1) Cathodic protection;
(2) Noncorrosive materials of construction; and
(3) Noncorrosive cladding of steel (coating).
A more complete description of these can be found in the text of this document.
Note that corrosion protection must be provided for the piping as well as for the tank. As stated
in the Interpretive Rule, the provisions of the Interim Prohibition apply to the tank and its attached piping.
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1.1.1 Cathodic Protection
Cathodic protection is a process by which corrosion of a metal surface is prevented by making
that surface the cathode of an electrochemical cell. The metal surface referred to is any surface of
the underground storage system, including the tank, piping, valves, pumps, and other appurtenances.
Note that merely installing a cathodic protection system does not ensure compliance with the law.
The cathodic protection system must provide sufficient electrical current to protect the underground
tanks and piping for their operational lives. This can be confirmed by measuring the structure-to-soil
potential as described in NACE RP-02-85, Control of External Corrosion on Metallic Buried, Partially
Buried, or Submerged Liquid Storage Systems, (National Association of Corrosion Engineers, 1985).
Galvanized pipe, alone, does not satisfy this requirement for two reasons. First, there is not enough
zinc coating on the pipe to provide sufficient protection under corrosive soil conditions. Second, it
is extremely difficult to assess the level of protection provided by the zinc after the pipe has been
buried. The bonding of the zinc to the pipe makes structure-to-soil potential measurement very dif-
ficult. Therefore, galvanized pipe must be supplemented with additional protection, such as coatings
and/or cathodic protection.
1.1.2 Noncorrosive Materials of Construction
Fiberglass-reinforced plastic (FRP) is the most predominant noncorrosive material used to manufac-
ture USTs and piping. Tank systems constructed from this material can satisfy the corrosion protec-
tion requirements of the Interim Prohibition. EPA is unaware of other materials which would satisfy
this requirement. In general, using metals other than mild steel does not satisfy the corrosion protec-
tion requirement. All metals are subject to corrosion if buried, although the rate and mechanism of
corrosion may vary with different metals. Only FRP possesses sufficient corrosion-resistance to satisfy
the corrosion prevention provisions of the Interim Prohibition without coatings or cathodic protection.
1.1.3 Noncorrosive Cladding
Another type of system which can comply with the Interim Prohibition is the steel tank coated
with FRP. There is currently some debate among corrosion control experts regarding the advisability
of using any coating without cathodic protection. The reasons for this concern are described in Sec-
tion 1 of this document. However, the Interim Prohibition allows the use of "steel clad with a non-
corrosive material" which includes FRP-coated steel. The key factors in the success of this coating
include its thickness, dielectric strength, durability, and good bonding to the steel. No national stan-
dards currently exist for this design. Manufacturers' standards, however, include the following:
(1) Minimum thickness of completed coating = .10 inch;
(2) Electric testing at a minimum of 10,000 volts to ensure complete coating of the tank.
These should be considered minimum standards for acceptability of FRP coatings. As consensus codes
or national standards become available, they may supplement or replace these minimum standards.
1.2 Structural Integrity
The Interim Prohibition also requires that tanks be installed to prevent releases due to structural
failure for their operational lives. Proper installation of underground storage systems is essential to
preventing structural failure. Therefore all USTs, regardless of their design, must be properly installed
to comply with the Interim Prohibition. Installation instructions provided by the tank manufacturer should
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OSWER DIR.9650.1
be followed. In addition, a document published by the Petroleum Equipment Institute provides a great
deal of information on the proper installation of underground storage tanks. This document, entitled
Recommended Practices for Installation of Underground Liquid Storage Systems (PEI/RP100-86),
describes proper procedures for installing all the components of an underground storage system, includ-
ing the tanks, pipes, fittings, and corrosion protection.
One of the keys to preventing structural failure, particularly for FRP tanks, is the proper selection
and installation of the backfill material used to support the tank. As described more fully in Section
2 of the document and in PEI/RP100-86, the tank relies on the backfill for some of its support. For
FRP tanks, the backfill provides as much as 90 percent of the tank's support. Therefore, failure to
properly backfill the tank can cause releases due to structural failure and would be a violation of the
Interim Prohibition. Tanks installed in accordance with the manufacturer's instructions and/or
PEI/RP100-86 are likely to comply the Interim Prohibition.
1.3 Installation of "Used" Tanks
It is important to emphasize that anyone who installs a "used" tank is also subject to the Interim
Prohibition. A used tank is one that was removed from the ground and is to be installed in the same
or at another site. These tanks must meet all of the requirements of the Interim Prohibition.
1.4 Secondary Containment
Secondary containment does not eliminate the need for corrosion protection. Double-walled steel
tanks must be coated with a noncorrosive material (FRP) or provided with cathodic protection to com-
ply with the Interim Prohibition (unless installed under the 12,000 ohm-cm exclusion). Single-walled
tanks installed within membrane liners must also be similarly protected from corrosion.
2. THE PROTECTION OF UNDERGROUND TANKS FROM CORROSION
Corrosion is one of the major causes of failure for underground storage tanks. Under the Interim
Prohibition, no underground tank can be installed unless it will prevent releases from corrosion for
the operational life of the tank. To ensure that such releases are prevented, the law requires that each
new tank and its piping must either:
• Be cathodically protected;
• Be constructed of noncorro'sive material;
• Be steel clad with noncorrosive material; or
• Be designed in a manner to prevent the release or threatened release of any stored substances.
This chapter contains a description of how and why an underground tank system corrodes and
examines how to protect a tank system from corrosion. Different types of corrosion protection devices
are identified and described, including how the devices work and their limitations. The concept of soil
resistivity and its role in the corrosion of underground tanks is also explained. Finally, secondary con-
tainment practices are described briefly, as a possible means of satisfying the option provided by the
Interim Prohibition permitting tanks to be designed in a manner that prevents the release or threatened
release of stored substances.
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OSWER DIR.9650.1
2.1 Causes of Underground Tank Corrosion
A metal underground tank is susceptible to corrosion when it contacts oxygen and moisture. Over
a period of time, the oxygen and moisture contribute to the breakdown of metal into its original state—an
ore. The visible results of corrosion of a steel or iron tank are often rusted areas that become increas-
ingly deep. This corrosion process can continue until it bores through a tank's metal thickness, creating
a hole. Even underground tanks that show only minor traces of scaling or rust on their outer surfaces
can have small holes that leak.
One of the most misunderstood aspects of the corrosion of underground tanks is that the forces
of corrosion can be accelerated underground. In general, the speed and severity of corrosion
underground depend on a number of factors, including soil conditions and tank characteristics. Cor-
rosion may occur over an entire surface of exposed metal or may be localized at a few spots. When
localized, the metal may corrode very quickly.
Localized corrosion is a result of uneven breakdown in the metal structure of an underground
tank. The corrosion is focused in small areas and can cause severe damage in these areas, while
leaving adjacent areas of a tank relatively untouched. This process can quickly create large holes
in an otherwise sound and undamaged underground tank.
Corrosion can occur from inside or outside a tank. External corrosion can be caused by galvanic
action or by stray currents. Internal corrosion is generally caused by galvanic action or is chemically
induced. These processes are described in the subsections below.
2.1.1 Galvanic Corrosion
Galvanic corrosion occurs where an electric current flows from the surface of a metallic structure,
such as a storage tank, into the surrounding environment, such as the soil. For this current to flow,
there must be a complete circuit, consisting of an anode and a cathode that are electrically connected
and placed in an electrolyte. This circuit, also called a corrosion cell, is demonstrated in Figure 2-1.
In the circuit, the anode is the metal, or location, at which current leaves the structure (tank). Corro-
sion occurs at this spot. The cathode is where the current re-enters the structure to complete the cir-
cuit. Corrosion does not normally occur at the cathode. The electrolyte carries the current between
the anode and cathode. For buried structures, soil is the electrolyte.
The final requirement for current to flow in the circuit is that differences must exist between the
electrically-connected anode and cathode. Some examples of these differences are dissimilar metals
(e.g., brass valve and steel pipe), scratched and clean surfaces, and varying soil composition along
the surface of the tank or pipe. Figures 2-2, 2-3, and 2-4 illustrate some of these situations. There
are other conditions under which these differences may occur, however, a complete catalog of these
conditions is beyond the scope of this document. What is important for a user of this manual to under-
stand is that the conditions necessary to allow the corrosion process to proceed can be brought about
in many ways, and these conditions are almost always present. It is, therefore, best to assume that
when a metal structure (tank or pipe) is buried, it will corrode. Measures to prevent this corrosion should
then be taken. These measures are described in Section 2.2.
The galvanic corrosion process, shown in more detail in Figure 2-5, continues to widen a hole un-
til the corroded tank or piping is repaired or replaced. In addition, other holes may also form simultane-
ously in the same general area. Corrosion points are usually highly localized in the corrosion process.
It is important to note that even very slight differences within the metal on the surface of a tank or
between different metals that are electrically connected in a tank system will cause galvanic corrosion.
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FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Cathod
l + l
Anode
l-l
Metallic Connection
I
' Electrolyte
RGURE 2-1 GALVANIC CELL
Corroding
Area
Backfill
• (Electrolyte)
'
(Anode)
Scratch
Metal
(Cathode)
Steel Alloy
Drop Tube
(Cathode)
RGURE 2-2 GALVANIC CORROSION ON AN
UNDERGROUD TANK SYSTEM
• Poorly Aerated Zone
Well Aerated Zone \ (Anodic)
(Cathodlc)
Water Table
Submerged
Area
(Anodic)
Bedding
RGURE 2-3 GALVANIC CORROSION CAUSED BY DIFFERENCES IN
SOIL AERATION & MOISTURE
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Excavation V
Limit
Metallic Connection
(Piping) 7
Bedding
Electrolyte
(Backfill)
FIGURE 2-4 GALVANIC CORROSION BETWEEN A NEW
TANK AND AN OLD TANK
Cathoda
Metallic Ions
Tank Wall
I Anode
Tank Interior Surface
Cathode
FIGURE 2-5 CORROSION PITTING ACTION
10
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OSWER DIR.9650.1
2.1.2 Stray Current Corrosion
If a subway system, gas distribution, power distribution, or some similar type of direct current
power system is in the vicinity of an underground storage tank system, parts of the tank system may
be subject to corrosion caused by stray currents. This type of corrosion results from direct currents
flowing from an external power source, through an underground path of least resistance, and back
to the source. If any portion of the metallic underground tank storage system is installed in the path
of stray currents, the current can flow through the tank system. This type of corrosion occurs at the
point where the current leaves the tank or piping (see Figure 2-6).
The rate at which this localized corrosion occurs is directly related to the intensity of the stray
currents. The larger the currents are, the faster the corrosion rate of a tank. Stray currents are often
many times stronger than the currents in galvanic corrosion. Therefore, stray currents can cause more
severe damage to underground tanks in shorter periods of time than galvanic corrosion. Stray current
corrosion may occur over a wide surface area of a tank and at some distance from a power source.
2.1.3 Internal Corrosion
Localized corrosion can occur inside underground tanks. This type of corrosion occurs in crevices,
seams, corners, shielded areas in tank interiors, and directly under the fill pipe. Such corrosion is
generally associated with small volumes of stagnant fluid (usually water) trapped by holes, gasket sur-
faces, pipe joints, and surface deposits. Over time, the chemical characteristics of the trapped fluid
may change, leading to chemical corrosion and acceleration of galvanic corrosion at these locations.
Impacts from tank dipstick operations and other internal stresses can form anodic areas, leading even-
tually to internal galvanic corrosion.
2.2 Types of Corrosion Protection
The Interim Prohibition identifies three specific methods intended to protect an underground tank
storage system from corrosion: cathodic protection, corrosion-resistant materials, and corrosion-resistant
coatings. According to the Interim Prohibition, such corrosion protection measures must be capable
of preventing releases due to corrosion for the operational lives of tanks. Subsections 1.2.1 through
1.2.3 describe these alternatives.
Section 2.2.4 describes the role of soil resistivity in preventing corrosion. Finally, Section 2.2.5
examines an alternative tank system design that EPA believes will satisfy the requirement for a tank
system "designed in a manner to prevent releases. .." This alternative tank system design is secon-
dary containment around a tank and its piping.
2.2.1 Cathodic Protection
As described earlier, underground tank corrosion is caused by an electrical current leaving a metal
and flowing to another portion of the metal or the soil. If the flow of current is reversed, corrosion of
the tank can be slowed or even stopped. Cathodic protection systems reverse current in one of two
ways: through sacrificial anodes or impressed current.
A. Sacrificial Anode Systems. Sacrificial anode corrosion protection functions on the principle of
galvanic corrosion: when two dissimilar metals in soil are connected to each other, a small current
will flow from the more electrically active to the less active metal, causing the more active metal to
corrode. Table 2-1 shows the Galvanic Series, which lists metals from top to bottom according to their
11
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OSWER DIR.9650.1
Table 2-1 Galvanic or Electromotive Force Series
Metal
Activity
Commercially Pure
Magnesium
Magnesium Alloy
Zinc
Aluminum Alloy
Commercially Pure
Aluminum
Mild Steel (clean)
Mild Steel (rusted)
Cast Iron
lead
Copper, Brass, Bronze
Carbon, Graphite.
Coke
High (tends
to corrode)
Low (tends
not to corrode)
Source: American Petroleum Institute Publication 1632.
12
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
D.C. Power
Source
Rails
Stray Electrical
Current
Underground
Steel Tank
FIGURE 2-6 STRAY CURRENT CORROSION
13
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OSWER DIR.9650.1
tendency to corrode. When a metal near the top of the list is connected to a metal lower on the list,
the metal which is higher on the list will corrode, sacrificing itself to protect the other metal.
Most sacrificial anode systems consist of a magnesium or zinc rod attached to an underground
storage tank. Because magnesium and zinc are more active than steel, for example, they will corrode,
rather than the tanks. By "sacrificing" themselves, the rods reverse the flow of current from the tank,
thus protecting the tank from corrosion (see Figure 2-7).
Sacrificial anode systems are most useful when the current required to protect a tank from corro-
sion is low. The number, type, size, and location of anodes can tie estimated based on the surround-
ing soil's resistivity (see Section 2.2.4), the.amount of metal surface area to be protected, and the
quality of a tank's coating.
Sacrificial anodes must be connected to a tank using a low resistance electrical connection. Welded
or brazed connections to a tank wall provide the surest electrical bond. Safety considerations may,
however, require the use of mechanical connections if flammable vapors are present that prevent
welding. Care must be taken to ensure that a good electrical connection is achieved with mechanical
connections. Connections must be protected from corrosion to prevent interruption of the cathodic
protection system in the future.
A piping system may require its own cathodic protection system. Though galvanized piping has
a limited amount of corrosion protection provided by its coating of zinc, this coating is often insuffi-
cient protection for the piping's operating lifetime. In addition, pipe threads that are not coated can
provide potential areas of galvanic corrosion (see Figure 2-8).
If a sacrificial anode system is used, it is often best to isolate a tank from its piping and protect
each separately. Figure 2-9 shows a tank system where separate sacrificial anodes cathodically pro-
tect the tank and the piping. It is also a good practice to isolate the electrical system that powers a
tank pump. Because the current output from a sacrificial anode system is limited, the amount of metal
on an underground tank to be protected should also be limited. To minimize the amount of protected
metal, one may install insulating bushings in pipe connections. Without these bushings, a cathodic
protection system would protect the piping as well as the tank. If the piping is connected to other struc-
tures, the burden on a protection system may be increased still more. As a result, there may be insuf-
ficient cathodic protection or a weak electrical circuit may be created that will cause corrosion on another
attached metal structure.
The system pictured in Figure 2-10 is "pre-engineered," i.e., a tank comes from the manufac-
turer with the anodes attached. Pre-engineered underground tank cathodic protection systems are
generally provided in a package consisting of anodes, insulating bushings, and a high-quality, corrosion-
resistant coating. These systems were developed to satisfy a range of soil conditions. There may,
however, be some sites that require systems designed specifically for the conditions at the sites. This
may be particularly true for sites tested to have either very low or high soil resistivity or where stray
currents are present. As with any system, pre-engineered systems should be handled and installed
carefully to avoid damage to any of the systems' components.
B. Impressed Current Protection Systems. Impressed current systems use alternating current
(AC) supplied from the electrical system at a site. The AC is converted to direct current (DC) by a
rectifier, and then the current flows to an anode, commonly made of carbon-containing rods. The electric
current supplied to this anode flows from the anode, through the soil, to the tank system. Corrosion
of a tank is prevented because the current flowing to the tank is greater than that flowing away from
the tank. Figure 2-11 illustrates an impressed current system.
14
-------
QSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Current
Metallic
Connection
\^^A^^^K^^^M^^^T
•__ Zinc or Magnesium
Anode
FIGURE 2-7 CATHODIC PROTECTION BY THE SACRIFICIAL
ANODE METHOD
15
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Corrosion
Moist
Earth
(Electrolyte)
Corrosion
Uncoated
Pipe Threads
(Anode)
Galvanized
Iron Pipe
(Cathode)
Scratches
(Anode)
RGURE 2-8 PIPE CORROSION
16
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Dispenser
Submersible Pump
^— Sacrificial Anode
\ r— Pavement
Insulating Union
Safety Valve
•ivieiai rressure ripe
nsulatlng Sleeve
Metal Manhole
. . . Plastic Sleeve
Isolated Connections'/.
(see Insert)
Sacrificial
Anode
Belt
\
Insulating Washer
Nylon InsulatiiK
/ Bushing
Cellar
Insulating Gasket
Nut
DETAIL-ISOLATED
MECHANICAL CONNECTION
DETAIL-ISOLATED NYLON
BUSHING CONNECTION
FIGURE 2-9 UNDERGROUND TANK AND PIPING SYSTEM
17
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Pre-engineered
Sacrificial Anode
Attached by
Manufacturer
FIGURE 2-10 PRE-ENGINEERED SACRIFICIAL ANODE SYSTEM
18
-------
OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
RECTIFIER
20-60 Volt D.C.
~ DC Current
to Anode Bed
Anode Bed
NOTE: Piping not shown for claiity
of drawing.
FIGURE 2-11 IMPRESSED CURRENT CATHODIC PROTECTION SYSTEM
19
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OSWER DIR.9650.1
The amount of electric current that must be supplied by a rectifier depends upon the current
required to protect a tank and the voltage needed to cause current to flow from the anodes, through
the soil, to the tank system. With an impressed current system, the current can be adjusted to meet
the requirements imposed by varying conditions. Current requirements can change as soil conditions
change, as a tank system is expanded, and as a tank's coating deteriorates. Impressed current may
also be changed with fluctuations in stray currents from nearby sources. All metal structures within
the electrical field created by an impressed current system must be properly connected to a tank
system's circuit. Otherwise, stray currents created by the system will cause accelerated corrosion of
the unconnected structures.
Users of impressed current systems are cautioned that limits should be placed on the output
capacity of a rectifier to prevent overloading the rectifier, as well as to protect the coating on a tank.
If more current is provided than is needed for corrosion protection, the excess current may cause
coatings to separate from structures.
Impressed current systems are more flexible than sacrificial anode systems and are capable of
providing more protection. Impressed current systems are, however, more expensive to install and
operate. As long as a tank is adequately coated and is isolated from piping, sacrificial anodes are
usually sufficient. If a tank is not coated or isolated, the coating is too thin, has holes in it, or deteriorates
with time, impressed current systems may be required. Impressed current systems are often recom-
mended to retrofit cathodic protection on older tanks, provided the tanks do not already leak.
C. Monitoring System Performance. Regardless of which cathodic protection system is selected,
some means should be provided to monitor performance periodically. A cathodic protection system
should be monitored because soil and tank conditions may change over the operational life of a tank,
altering cathodic protection needs. In addition, problems with a cathodic protection system should
be detected promptly.
Monitoring cathodic protection system performance is done by periodically measuring the structure-
to-soil potential (the voltage between a tank and its surrounding soil). If the voltage is higher in the
soil than in a tank, then current is flowing from the soil to the tank, thereby blocking corrosion. A generally
accepted standard for providing adequate tank protection is that the structure-to-soil difference in voltage
should be at least 850 millivolts negative, as measured by a copper-copper sulfate electrode. This
device is commonly used by corrosion control engineers. Other types of devices are also available.
Figure 2-12 shows the use of an electrode to measure structure-to-soil potential. A lead from a
tank is connected to a voltmeter, which is connected to an electrode. The electrode is then placed
on the soil, as close to the tank as possible (but not over any sacrificial anodes). Although the measure-
ment procedure itself is quite simple, it is best done by an experienced operator who understands
the proper placement of the reference electrode. A common measurement error is placing the elec-
trode on the concrete pad over the tank. This leads to erroneous readings. To avoid errors created
by improper placement, a permanent electrode can be installed in the ground. This should be done
by someone experienced in corrosion control. It must be noted that "permanent" electrodes have
a limited service life and must be replaced as necessary.
In addition to proper placement of a reference electrode for measuring system performance, a
good electrical connection to a tank is necessary to complete the electrical circuit. This can be done
by attaching the measuring wire to a tank with a welding process. If the tank is coated (as it should
be), the tank manufacturer should provide a connection point before applying the coating. When this
is not done, it may be possible to connect the test lead to a lifting lug. Before doing this, however,
the tank manufacturer should be consulted. Tampering with a tank in this way without the
20
-------
OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Voltmeter
Structure
Contacting
Probe
/ • .'
Copper
Sulfate
Halfcell
Electrode
Note: Probe must contact tank If tank
is electrically isolated from piping
FIGURE 2-12 STRUCTURE TO SOIL MEASUREMENT SYSTEM
21
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OSWER DIR.9650.1
manufacturer's approval may void a tank's warranty. It is also a good idea to install permanent manholes
to provide access to the soil near a tank when there are no permanent reference electrodes.
Additional information on structure-to-soil potential measurement and standards for determining
adequate protection can be found in API Publication 1632, Cathodic Protection of Underground
Petroleum Storage Tanks and Piping. Systems (1983) and the National Association of Corrosion
Engineers (NACE) Standard RP-02-85, Recommended Practice for Control of External Corrosion on
Metallic Buried, Partially Buried or Submerged Liquid Storage Systems (1985).
2.2.2 Noncorrosive Materials of Construction
As an alternative to installing cathodically protected steel tanks, the Interim Prohibition allows
tanks and piping to be constructed of noncorrosive materials. The most commonly used nonmetallic
corrosion-resistant material is fiberglass-reinforced plastic (FRP). Although FRP tanks are generally
referred to in a way that denotes a single type of storage tank they can, in fact, actually be fabricated
from a wide variety of plastic resins. The selection of plastic resin depends upon the material to be
contained and the conditions of storage. Tank material selection is discussed in more depth in Chapter
4 of this guidance document.
Most FRP tanks now in use are constructed from isophthalic polyester resin, which has been found
suitable for petroleum product storage by Underwriters' Laboratories, Inc. (UL). These tanks are gener-
ally constructed to UL Standard 1316, Standard for Safety—Glass-Fiber-Reinforced Plastic Underground
Storage Tanks for Petroleum Products (1983). This standard specifies tank capacities, fittings, and
testing procedures.
The primary advantage of FRP is that, given its inherent noncorrosive nature, it can be installed
in a wide range of soil conditions without concern for corrosion protection. On the other hand, FRP
tanks may be somewhat more sensitive to mishandling during installation than steel tanks. FRP tanks
are lighter and slightly less flexible than steel, relying on backfill to supply as much as 90 percent
of their structural support. FRP tank manufacturers have developed detailed handling and installation
procedures that should be followed by tank installers. When knowledgeable, well-trained installers
carefully follow all these procedures, FRP tanks should retain their structural integrity during use.
Chapter 3 contains further information on installation procedures.
FRP piping is also available. As with FRP storage tanks, FRP piping resists corrosion. FRP pip-
ing must be handled differently than steel piping, however, in order to provide effective containment.
For example, FRP piping joints are sealed with adhesives that are temperature sensitive. During col-
der weather (lower than 60° F), adequate heating equipment must be used to ensure proper sealing.
These joint adhesives may also be subject to chemical attack when used to store materials other than
petroleum. When selecting an FRP piping system, one must consider compatibility of the piping joint
adhesive with the stored substances.
2.2.3 Steel Clad with Noncorrosive Material
As discussed previously, galvanic corrosion only occurs when four elements are present: an anode,
a cathode, an electrolyte, and an electrical connection between the anode and cathode. Nonconduc-
tive coatings can be used to separate a tank from the soil electrolyte. When this is done effectively,
corrosion will not occur.
The effectiveness of any coating depends on its insulating characteristics, thickness, and the com-
pleteness of its coverage. If there is a flaw in a coating (known as a "holiday"), the corrosion-producing
22
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OSWER DIR.9650.1
electrical currents will concentrate at the flaw and corrosion will occur there at an accelerated rate.
Scratches on the exterior of a tank from improper handling or installation can cause corrosion pro-
blems. To protect against this occurrence, a coating should be checked by an electronic holiday detector
before a tank is placed in an excavation. Any damaged areas should be repaired using the same coating
material that is on the tank. In actual practice, coatings are rarely perfect, and there are almost always
some flaws. Thus, the primary function of a coating is to reduce rather than to eliminate the surface
area of exposed metal, thereby decreasing the amount of cathodic protection needed.
An important factor in selecting a coating is its durability. Many coatings may be soluble in the
products stored in the tanks. For example, the asphalt paints used on many gasoline tanks now in
place are soluble, in varying degrees, in gasoline. This is a concern, even if a tank system is not leak-
ing, because surface spills can occur during normal operations that can penetrate soil and damage
a coating. The areas of a tank with damaged coating may then lose their protection from the surround-
ing soil and be subject to corrosion. Thus, asphalt paints on steel gasoline tanks do not meet the Interim
Prohibition requirement for steel clad with non-corrosive material. A coating may also dry and crack
during the normal operation of a tank, resulting in reduced protection.
Coal tar epoxy and FRP are becoming increasingly popular as tank coatings. A coating of coal
tarepoxy is typically 15 mil. (15/1000 inch) minimum dry film thickness, while an FRP coating is about
125 mil. thick. These materials are durable and provide effective electrical insulating qualities but,
as with other materials, they are subject to reduced effectiveness from inadequate surface prepara-
tion, improper application, too little material used (or too few coats), and excessive damage during
shipment or installation. Asphalt and lead-based paints are generally poor coatings for tanks storing
petroleum liquids or solvents because they are likely to dissolve if in contact with the stored product
and do not provide adequate electrical isolation.
2.2.4 The Exemption from Corrosion Protection Requirements
The Interim Prohibition allows installation of tanks without corrosion protection in soil with a resis-
tivity of 12,000 ohm-cm or higher (electrical resistance determined across a 1 -centimeter cube of soil),
measured using ASTM Method G57-78, the "Wenner Method." Resistivity measurements indicate
a soil's ability to prevent the flow of electricity. Such measurements are used to estimate cathodic
protection needs.
Although a tank can be installed legally without corrosion protection in soil with a resistivity of
12,000 ohm-cm or higher, the tank may still be subject to leaks from corrosion. Therefore, EPA
encourages persons who are considering installing a metal tank under the exemption requirement
to take other relevant soil characteristics into consideration prior to installing a nonprotected tank.
Since a copy of ASTM Method G57-78 is included in Appendix E, a detailed explanation of the
testing method will not be included here. A brief description of the information provided by the test,
along with the test's limitations is, however, provided below.
ASTM Method G57-78 provides an on-site means of measuring the resistivity of soil. The measure-
ment yields an average resistivity of a hemisphere of soil with a radius equal to the distance between
the method's electrodes. Because the resistivity measured is the average resistivity of the soil on the
day of measurement, there are three limitations. First, soil is often not uniform throughout its depth
or over a. wide area. This means that over an 8- to 12-foot depth (the depth at which a tank is installed),
there may be narrow strips or small areas of low resistivity soil within wider strips of high resistivity
soil. Under these conditions, the method may yield results indicating a high average resistivity,
23
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OSWER DIR.9650.1
masking the areas of low resistivity. Should a tank without corrosion protection be installed under these
conditions, it could corrode very quickly in the presence of the low resistivity soil layers.
The second limitation involves the wide variation of soil resistivity measurements in different levels
of moisture. If the test is run during dry conditions, the measured resistivity could be very high. If,
however, the location is subject to periodic rainfall or variations in ground water level, the resistivity
could change dramatically with variations in these conditions. Resistivity can also differ widely from
season to season, as well as with soil depth. An unprotected storage system could be subject to accel-
erated corrosion rates during periods of high soil moisture content.
A third limitation is that resistivity measurements do not account for other factors that cause cor-
rosion, for example, stray currents and nitrate, sulfide, and chloride levels influence soil corrosivity.
Nitrate and sulfide levels can indicate the potential for bacterial corrosion. While the bacteria themselves
do not directly affect corrosion, their activity can create corrosive conditions around a tank storage
system. High chloride levels increase a soil's electrical conductivity. Chloride levels can be increased
by salt applied to streets and highways during the winter. These salts may penetrate the soil through
cracks and joints in pavement and decrease soil resistivity. Although the effect would not be detected
by resistivity testing when soil is dry, it causes the soil, when wet, to become an excellent electrolyte
that fosters accelerated corrosion because the chlorides go into solution.
Additional factors that contribute to soil corrosivity besides sulfide and chloride levels include acidity
(pH), dissolved oxygen content, oxygen level differentials between the bottom and top parts of tanks,
and many others. Simple resistivity measurements will fail to discover many of these factors. A reliable
method for combining all the relevant factors to predict corrosivity accurately has not been developed.
Furthermore, detailed soil analysis is generally more expensive than providing corrosion protection.
For this reason, many corrosion control engineers recommend assuming that all soils are corrosive
and they use resistivity measurements to design appropriate cathodic protection systems.
2.2.5 Secondary Containment Systems
Another method commonly used to reduce environmental releases from underground tanks is
installing a secondary containment system. These systems are designed to contain leaks or spills tem-
porarily, preventing them from contaminating the surrounding environment. Secondary containment
is not a long-term storage solution by itself. Such systems should always be coupled with a leak detection
system within the secondary containment that informs a tank operator when a tank is leaking so that
the situation can be rectified while the release is still within the secondary containment system. A
tank with secondary containment is subject to the same need for corrosion protection as any other
metal tank. To be effective, the secondary containment system must be installed with as much care
as a properly installed tank.
Secondary containment systems may include:
• Double-walled tanks;
• Pit lining systems; and
• Vaults.
The following three subsections provide brief descriptions of these secondary containment systems.
The last subsection briefly addresses secondary containment of piping.
A. Double-Walled Tanks. Double-walled tanks constructed of either steel or FRP represent one
type of secondary containment. Several double-walled designs are now available, and more are
24
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OSWER DIR.9650.1
expected to become available in the near future. Double-walled tanks consist of a tank within an outer
shell. The outer shell may completely surround an inner tank or, in some cases, leave the top of the
inner tank exposed. Examples of double-walled tanks are shown in Figure 2-13.
The space between the inner and outer walls (the interstitial space), which may be used for leak
detection, can either be pressurized or made into a vacuum in order to discover leaks. Other leak
detection systems install a device in a standpipe that is able to detect any liquid entering the space.
Still another type of detection device fills the space with a liquid (e.g., water) and uses a monitor that
reflects any changes in liquid level or electrical properties. The interstitial leak detection system informs
a tank operator when either the primary or secondary wall is leaking.
Double-walled tanks commonly available today provide a high degree of environmental protec-
tion along with a means for detecting leaks. They are, however, still subject to the corrosion and struc-
tural stresses that affect single-walled tanks. Under the Interim Prohibition, these tanks must be pro-
tected accordingly. Thus, a metal double-walled tank must be cathodically protected from corrosion
and an FRP tank must be installed properly to prevent structural failure. Furthermore, the second wall
increases the weight of a tank significantly, particularly if it is constructed of steel, thus requiring a
more powerful crane for installation. A tank manufacturer should provide detailed installation instruc-
tions for double-walled tanks, particularly where the installation process differs from that for single-
walled tanks.
B. Pit Lining Systems. Another means of secondary containment is to line the pit in which an
underground tank is to be placed with a material impervious to the substance being stored. The materials
usually used for such systems include the following:
• Low permeability constructed barriers—clay, soil cement, bentonites, asphalt, grouts, soil
sealants; and
• Synthetic membrane liners.
Figure 2-14 illustrates a pit lining system.
It is important to include a liquid monitoring and removal system as part of this type of secondary
containment system. The floor of a containment pit should be sloped to a sump from which a sample
can be taken to determine if the contents of a tank are leaking into the secondary containment area.
The top of a secondary containment area should have an impervious cover (e.g., paving, clay
cap, etc.) to prevent rainwater from accumulating within the pit liner. If no cover is provided, accumulated
rainwater that percolates to the liner should be removed by pumping or by some other drainage system.
Selection of the proper pit lining material for a particular use depends on several factors including
the following:
• Type of Material Being Stored. Consideration should be given to the compatibility of a liner with
the liquid being stored. The lining material must be able to maintain its integrity and impermea-
bility if exposed to stored product. Chapter 3 examines compatibility considerations in more
detail.
• Local Environmental Conditions. The sensitivity of the environment in the vicinity of a storage
facility can largely affect the choice of containment liner required. For example, a high water
25
-------
OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Outer Wall Ends Here
On Some Tanks
Sampling
Standplpe
or
Electronic
Liquid
Detection
Pre-engineered
Sacrificial Anodes
Exterior Protection:
- Coal-tar epoxy with
sacrificial enodes; or
- FRP Coating
DOUBLE-WALLED STEEL TANK
Interstitial Space
I
NOTE: May not be present for electronic monitoring
DOUBLE-WALLED FRP TANK
FIGURE 2-13 DOUBLE-WALLED TANK CONFIGURATION
26
-------
OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Monitoring/
Recovery Wall
Pavement
SECONDARY
CONTAINMENT
LINER
Clay
Bentonite
Soil Cement
Asphalt
Synthetic Textile
Sacrifical Anode
(Steel Tanks Only)
STEEL OR FRP TANK
Backfill
Bedding (Pea Gravel or Sand)
Slope base to well
Well Pit
FIGURE 2-14 SECONDARY CONTAINMENT USING LINER TECHNOLOGY
(Dry Installation-Not to be used in high ground water)
27
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OSWER DIR.9650.1
table might require a particularly strong, impermeable liner and ballasting system to protect the liner's
physical integrity. Proximity to ground water used as a public drinking water supply may require greater
care in the selection and installation of a containment liner. Extreme temperature conditions may also
require selection of a liner with appropriate physical properties.
• Legislative Requirements. State and local governments and/or authorities may have regulations
that are very detailed in terms of the type of containment barrier required.
• Economics. Some lining systems are very expensive in certain applications, particularly in high
ground water situations. Economic analyses may show other secondary containment systems,
such as well-designed, double-walled tanks or vaults, to be more cost effective.
• Installation. The performance of all pit lining systems is highly dependent on installation methods.
Regardless of the lining system chosen, the installation process should be closely monitored
for compliance with competent plans and specifications.
(1) Low-Permeability Constructed Barriers. The following materials can prevent liquids from passing
through them to reach the ground water. The differences between the various barriers are described
below.
(A) Clays. Clay is a relatively inexpensive material for secondary containment and is often read-
ily available. Clay varies in composition and permeability and is subject to drying, cracking, and
destabilization when exposed to some organic solvents. Clay may also be permeable to some materials,
particularly after exposure to water. Furthermore, installation of clay liners can be extremely complex,
as it depends heavily on the characteristics of a site and of the clay itself. To be adequately designed
to prevent releases, the excavation must be free of water, and the clay liner must be sufficiently thick,
well compacted, and installed at the proper moisture content.
(B) Soil Cement. Soil cement is an engineered mixture of suitable native soil material, an appro-
priate grade of Portland cement, and water. Proper mixing and placement create a low compressive
strength mixture that can be placed and compacted to make a barrier of medium to low permeability,
depending on the type of soil used. Soil cement is durable and resists aging and weathering, but
degrades rapidly in areas of high frost penetration. It can also serve as a base or foundation for a
membrane liner.
(C) Bentonite. Bentonite is a natural material that is similar to clay in its low permeability, self-
sealing, and good aging characteristics. Bentonite may deteriorate when exposed to some contaminants
and organic solvents. In addition, use of bentonite requires a protective soil cover and low ground
water conditions.
(0) Asphalt. Asphalt cement is similar to road-paving material. Asphalt has good strength and
durability and is relatively impermeable when properly sealed. This coating should not be used to store
hydrocarbon volatiles, such as gasoline, however, because the hydrocarbons cause asphalt to
destabilize rapidly.
(2) Synthetic (Polymeric) Membrane Liners. Synthetic membrane liners provide acceptable secon-
dary containment for petroleum products on a temporary basis. For other liquids, the synthetic liner
must be nonpermeable to the substances that are contained and be resistant to chemical attack from
the substances. Synthetic liners can be fabricated from a wide variety of polymers, including polyvinyl
chloride (PVC), polyethylene, chlorosulphanated polyethylene, butyl rubber, epichlorohydrin, and
28
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OSWER DIR.9650.1
neoprene. The appropriate material is selected on the basis of compatibility of the liner with the stored
substances, permeability, durability, and the liner's ability to resist damage during installation.
Liner installation presents a complex task and should only be performed by a construction con-
tractor who is experienced and properly equipped. Proper installation involves, among other things:
• A well-compacted excavation base to prevent settling under a liner after a tank is installed;
• A stable slope for the excavation walls to prevent collapse after a liner is installed;
• Removal of rocks, rubble, and debris at the base and walls that could puncture a liner; and
• Special care and attention during construction to ensure that the seams and joints of a liner
are properly sealed.
(3) Vaults. The last type of secondary containment discussed is a concrete vault (see Figure 2-15).
A vault consists of a concrete floor upon which a tank is supported, and four concrete walls and a
roof. If the interior of a vault is to remain open (free of backfill), several things must be considered.
First, if the stored substances are flammable, a flammable or explosive mixture could form within the
air space of the vault if a leak occurs. Second, the tanks installed in a vault must be designed for
aboveground applications. As discussed earlier, tanks constructed for underground use often depend
heavily upon backfill for support. Third, liquids may leak through a concrete vault if improperly con-
structed. Although the concrete vault may delay the release of leaked material to the environment,
it should not be assumed that it will prevent leakage. The concrete vault may, however, be lined with
a synthetic material to prevent leakage. Concrete is also subject to cracking as a result of settling,
frost heave, etc. When the concrete cracks, the liner may also crack.
(4) Secondary Containment of Piping. In manners similar to those used for tanks, piping may also
be placed in secondary containment. Double-walled piping may be installed, the piping trench may
be lined, or piping may be installed in a vault. Piping and piping trenches should be installed so they
slope toward a tank; thus, any remainder in the piping and any spills will drain to the tank. Each of
these secondary containment methods will contain leaks or spills temporarily, preventing them from
contaminating the surrounding environment.
3. THE PROTECTION OF UNDERGROUND TANKS FROM STRUCTURAL FAILURE
The proper design and installation of an underground tank is necessary to ensure that normal
operational loads will not cause the tank to deform and rupture. The Interim Prohibition requires that
every underground tank installed after May 7, 1985 be designed to prevent releases from structural
failure for the operational life of the tank. Used tanks, i.e., tanks removed from the ground and rein-
stalled, are covered by the requirements of the Interim Prohibition.
This chapter provides a brief description of structural failure and its causes. The necessity to adhere
to proper installation procedures is emphasized. Prevention of structural failure by selecting an appro-
priate tank design is also addressed.
3.1 Causes of Underground Tank Structural Failure
Most standard tanks in current use, regardless of the construction materials, have been profes-
sionally designed and tested to withstand normal operating conditions and loads with a comfortable
29
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OSWER DIR.9650.1
RGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Monitoring/
Sampling
Probe
Sealed Access
Manhole
Fill Tubes
(Seal joints)
Backfill
Vault exterior
covered with
moisture barrier/ -^
waterproofing
Tank Bedding
Sub-bedding
Note: Tanks must be designed to
withstand internal forces
without backfill support.
FIGURE 2-15 SECONDARY CONTAINMENT VAULT
30
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OSWER DIR.9650.1
margin of safety. The most common cause of structural failure is improper installation. Improper installa-
tion is a term that encompasses a multitude of potential problems. Some of the most common installa-
tion mistakes that can lead to structural failure are the following:
• Inadequate pit and trench design;
• Improper handling of a tank at a site;
• Improper tank bedding and placement;
• Poor or unsuitable backfill material and/or compaction procedures;
• Improper tank depth;
• Inadequate, or nonexistent, anchoring in high ground water table conditions; and
• Improper installation of attachments, particularly piping.
Proper installation practices, described in Section 3.2, should minimize the likelihood of these mistakes
occurring and causing structural failure.
Installing a tank that is physically inadequate to meet the stresses at a site can also result in struc-
tural failure. Section 3.3 discusses design considerations to assist tank owners in selecting tanks that
are structurally secure.
3.2 instaliation Considerations
The environment surrounding an underground tank must be adequately characterized before a
tank is installed. Environmental factors that can affect siting and installation decisions include:
• Bedding and backfill characteristics;
• High water level, requiring a tank to be anchored;
• Location and magnitude of soil loads over a tank; and
• Likelihood of earthquakes.
Information on proper tank installation procedures is given in local consensus codes; such guidance
is, however, often inadequate because details are frequently vague in these codes. The most com-
monly available codes and recommended practices (RPs) that cover underground tank installation
are NFPA 30, Flammable and Combustible Liquids Code (1984) and API Publication 1615, Installation
of Underground Petroleum Storage Systems (1979). These documents were developed for petroleum
storage, but installation procedures for tanks used in other liquid storage situations are very similar.
The primary difference may be in the selection of storage system components. In addition, tank
manufacturers have developed very detailed, explicit installation recommendations. If these recom-
mendations are followed carefully, many installation problems that may lead to eventual tank failures
can be avoided.
31
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OSWER DIR.9650.1
The following subsections highlight some of the most important steps in proper installation of
underground storage tanks. They are not intended to be detailed explanations of tank installation pro-
cedures. For more detailed guidance, a tank owner should refer to the codes and RPs and the instruc-
tions provided by the tank manufacturer.
3.2.1 Excavation
The size of the pit excavated to hold a tank is important. The pit should be deep enough to allow
for a tank's diameter, with sufficient space at the top and bottom for tank bedding, and space for sur-
face cover sufficient to protect the tank from the weight of vehicular traffic. A pit should be wide enough
to permit sufficient space between tanks (if there is more than one tank) and between pit walls and
tanks so that sufficient backfill can be added to support the tanks evenly (see Figure 3-1). Deep pits
in unstable soil conditions may require extra support (shoring) to prevent cave-ins.
If the ground water table is high, the pit may fill with water during excavation. A tank can, never-
theless, be installed properly in a wet pit if the procedure is performed by a competent contractor
who has had previous experience with such installations. A tank in this environment must be properly
secured, as discussed in subsection 3.2.3 below.
3.2.2 Tank Bedding
As part of proper installation, a tank should not be placed directly on native soil. A granular bedding
material should be placed on the pit bottom to provide an even bearing surface upon which the tank
will rest. Pea gravel, clean sand, or crushed stone should be used to form a uniformly supporting cradle
around the tank. Care must be taken not to leave any voids around the base (see Figure 3-2). Voids
can magnify the effects of structural loading and, if severe, can cause a tank to bend or crack. Sand
requires mechanical compacting to provide adequate support and to reduce the possibility of voids
developing.
Proper handling of a tank before and during installation is necessary to avoid damaging the tank
or its coating. This includes the use of lifting equipment of sufficient size and power to handle the
tank, using lifting lugs attached to the tank, or special lifting slings. A tank should never be dropped
or rolled into position. Improper tank handling can immediately lead to leaks following installation or
can later shorten the life of a tank.
The entire tank system should be tested for leaks before backfilling. Leak testing for new systems
involves pressurizing a tank aboveground and, coating it with a soapy water solution. Any bubbles
indicate a leak that should be repaired. After repairs, a system should be retested before burial. A
tank must not be pressurized beyond design standards during testing. Piping should be isolated from
the tank and tested with air pressure and soapy water solution. Air pressure testing should never be
done on tank systems once they have been buried. This type of testing is suitable only for new
equipment.
Once a tank base has been firmly seated and backfilled and the tank's appurtenances installed,
the balance of backfill can be placed in the excavation. Pea gravel, and crushed stone are relatively
self-compacting, provide firm support to a tank, and are easy to place. Clean sand is also an excellent
backfill material, but should be mechanically compacted to provide proper support. The soil previ-
ously taken from an excavation should not be used as backfill, unless such use is approved by the
engineer or technical representative of a tank supplier. If native soil is used as backfill, it should be
replaced in layers and each layer compacted to the level specified by local standards, or as recom-
mended by an engineer.
32
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Unstable .
Soil
Note: • Space In accordance with
manufacturer's installation
FIGURE 3-1 EXCAVATION instructions.
Bedding
J
Void Space
FIGURE 3-2 BEDDING
33
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OSWER DIR.9650.1
3.2.3 Tank Anchoring
Failure to secure a tank properly under high ground water conditions may result in the tank being
forced up out of the ground by the buoyant forces exerted upon it. Tanks may be secured in a number
of ways. Some rely on the weight of soil and a concrete driveway slab to hold the tank down from
above. Others rely on anchor straps around the tank, fastened to concrete. Tank anchors should be
supplied with a tank and installed by knowledgeable contractors. If a tank is to be anchored to a con-
crete slab, it should not be set directly on the slab, but separated from the slab by at least 12 inches
of bedding, as specified in API 1615 (see Figure 3-3). Anchor straps should be placed on a tank in
a manner that avoids damaging the tank or its coating, and the anchors should be electrically insulated
from the tank.
3.2.4 Piping
AP11615 outlines installation procedures for tank piping (see Figure 3-4). In general, piping should
be installed in adequately sized trenches and buried in sand or gravel, as is the tank. In addition,
piping should be sloped toward a tank to allow product to drain back to the tank. Finally, as advocated
in API 1615, swing joints or some other type of flexible coupling should be used where piping con-
nects to a tank, to allow for postinstallation shifting and settling. Swing joints may not be necessary
for FRP piping if a sufficiently straight run of piping is provided between a tank connection and the
next pipe bend. Installers should refer to API 1615 and the manufacturer's specifications for more
detailed guidance on installing a tank system.
3.2.5 Other Attachments
Access manholes should not rest directly on top of a tank. Adequate clearance should be left
so that the loads on a tank are transferred to the backfill (see Figure 3-5). Paving over tanks in traffic
areas should extend at least one foot beyond the perimeter of the tanks. Otherwise, a heavy vehicular
load on the top of a tank may lead to structural failure. The same consideration applies to vent place-
ment and the locations of other tank accessories.
3.3 Tank Design Considerations
In addition to proper installation practices, a tank and its attachments must be designed to withs-
tand the forces acting on the system. Such forces are illustrated in Figure 3-6. Underwriters'
Laboratories, Inc. (UL) Standards 1316 Glass-Fiber-Reinforced Plastic Underground Storage Tanks for
Petroleum Products and 58 Steel Underground Tanks for Flammable and Combustible Liquids can assist
in designing and testing tank systems for structural integrity. Tank structural integrity warranties are
based on these standards.
UL listing of a tank provides some assurance that a tank's design meets certain minimum stan-
dards. There may be other designs, however, that provide adequate structural integrity without meeting
UL standards.
4. THE COMPATIBILITY OF UNDERGROUND TANKS WITH SUBSTANCES STORED
The substance stored in an underground tank can adversely impact a tank's structural sound-
ness if the materials are chemically incompatible with the tank's liner or construction material. The
Interim Prohibition requires that an underground tank cannot be installed after May 7, 1985 unless
34
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Water
Table
Reinforced
Concrete
Anchor Pad
Anchor Strap & Pad
Bedding
FIGURE 3-3 TANK ANCHORING CONCEPT
Check
Valve
• Reinforced
Concrete
.Slab
4-.U- : -.*..'«
Suction Ljne (Slope to;/:
Manhole
Fillcap
2- Clay Tile • ,' . 'ifl!!4*5f"
t- Overfill
J? Float Ve
?
Soil
Backfill '
(Sand or
Gravel)
Source: API Publication 1615 Installation of Underground Petroleum Storage Systems, 1979
FIGURE 3-4 TANK PIPING DETAILS - SUCTION SYSTEM
35
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OSWER DIR.9650.1
ONLY- ™EY ARE NOT
Anchor
FIGURE 3-5 NORMAL TANK LOADS
36
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OSWER DIR.9650.1
FIGURES ARE FOR ILLUSTRATIVE PURPOSES ONLY. THEY ARE NOT INTENDED
FOR USE AS CONSTRUCTION DRAWINGS.
Tank Weight
(Dead Load)
Tank Contents
(Live Load)
Truck Load
(Live Load)
Soil Pressure
(Dead Load)
Anchor
Forces
Water Pressure
Soil Resistance
Pressure
Buoyancy
FIGURE 3-6 TANK LOAD SCHEMATIC
37
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OSWER DIR.9650.1
the lining and construction materials of the tank are compatible with the substance stored. Chemical
incompatibility can result in accelerated corrosion, cracking, and/or increased permeability (seepage
through) a tank's structure, thus causing leaks.
This chapter provides some general guidance on compatibility and how to attain it. The chapter
includes descriptions of some tank liner and construction material characteristics that can be used
to predict compatibility with stored substances.
4.1 Compatibility Considerations
Compatibility is an important concern when selecting a new tank. Some examples of chemicals
that are incompatible with specific types of tank liner and construction materials are listed in Table
4.1. (This list is not intended to be all-inclusive.) Under the Interim Prohibition, compatibility must be
maintained throughout a tank's operating lifetime. Further details on tank liners are contained in Sec-
tion 4.4 of this document.
The tank owner should consult with tank and resin suppliers regarding special storage require-
ments. Tank suppliers are equipped to make tests to establish compatibility of a substance with its
container, if compatibility information is not otherwise available. Corrosion, swelling, loss of strength,
etc. can be detected in laboratory experiments. Selection of a tank's construction material and design
thickness may be dependent on laboratory compatibility test results. Most reputable tank and resin
suppliers will assist in making the compatibility determination. Future uses of a tank must be con-
sidered when content compatibility is the goal.
4.2 FRP Alcohol Compatibility
Concerns have been raised that storage of alcohol or of gasoline/alcohol mixtures adversely affects
the structural integrity of FRP tanks and may lead to their structural failure. However, research into
these concerns has failed to discover any documented instances of an FRP tank failure attributable
directly or indirectly to storage of such substances.
Certain types of FRP tanks are currently available to store 100 percent methanol and ethanol
blends. These tanks are lined with a type of vinyl ester resin. Most of the FRP tanks now in service
are the standard polyester tanks used to store motor fuels and gasoline/alcohol blends consisting usually
of mixtures containing up to 10 percent ethanol or 5 percent methanol. Current testing methodology
established by Underwriters' Laboratory (UL) requires that FRP material flexural strength and hard-
ness retain at least 50 percent of their original values after 270 days exposure. While these criteria
bear no direct correlation to useful tank service life or to the rate of change of tank properties under
field conditions, they do give a general indication of content compatibility.
Resin manufacturers, tank manufacturers and chemical companies are performing research regard-
ing the effects of several types of alcohol (ethanol, methanol, etc.) and blends of gasolines of different
grades mixed with these alcohols on FRP tank construction materials. Many of these research testing
programs are on-going.
Available UL testing data indicate that the relatively new terephalate resins used for some types
of FRP tanks meet UL criteria when exposed to 100 percent methanol and ethanol blends. This is
supported by industry data.
38
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Table 4-1 Compatibility Chart: Structural Materials vs. Chemical
OSWER DIR.9650.1
Construction
Material
Generally
Incompatible with:
Steel
Aluminum
Magnesium
Lead
Copper
21nc
Tin
Titanium
Fiberglass- Reinforced Plastics
Mineral acids; nitric, hydrochloric,
dilute sulfuric acids
Alkalies; potassium hydroxide,
sodium hydroxide, mineral adds
Mineral adds
Acetic add, nitric add
Nitric add, ammonia
Hydrochloric add, nitric add
Organic adds, alkalies
Sulfuric add, hydrochloric add
Sulfuric add 95%. nitric add SOX.
hydrofluoric add 40%, aromatic
solvents, ketone solvents,
chlorinated solvents
Lining
Material
Generally
Incompatible with:
Alkyds
Vinyls (polyvinylchloride-PVC)
Chlorinated Rubbers
Epoxy (aminecured, polyamide
cured, or esters)
Coal Tar Epoxy
Polyesters
Sillcones
Strong mineral acids, strong
alkalies, alcohol, ketones, esters,
aromatic hydrocarbons
Ketones. esters, aromatic
hydrocarbons
Organic solvents
Oxidizing acids (nitric acid).
ketones
Strong organic solvents
Oxidizing acids, strong alkalies.
mineral adds, ketones, aromatic
hydrocarbons
Strong mineral acids, strong
alkalies, alcohols, ketones,
aromatic hydrocarbons
39
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OSWER DIR.9650.1
Available industry test data also show that standard fiberglass tanks exposed to 5 percent methanol-
gasoline blends and 10 percent ethanol-gasoline blends meet UL criteria. No corresponding UL data
are available.
It must be recognized that the useful service life of an underground tank installed at the present
time could be greater than 30 years. In the future, there is a possibility that higher percentages of
alcohol or other additives may be blended with gasoline stored in standard FRP tanks. If the reader
is planning to install an FRP tank that may be used in this manner during its service life, he should
discuss this situation with the tank manufacturer and/or supplier.
4.3 Characteristics of Tank Liner and Construction Materials
A tank liner or construction material's resistance to the following factors can be used to predict
compatibility with a substance that is stored:
• pH extremes;
• Chlorides and fluorides;
• Oxidation; and
• Solvent action.
If any stored substances display these characteristics, the substances can have adverse effects on
tank liner and construction materials. These effects will increase with elevated temperatures. Each
of the above characteristics is discussed below.
4.3.1 pH Extremes
Acids with a pH of 0 to 2 are highly corrosive acids, and alkalines with a pH of 12.5 to 14 are
highly corrosive bases. Such liquids can, depending on temperature, tank agitation, and tank con-
struction material, uniformly dissolve a significant percentage of the thickness of metal walls. Local
corrosion can be even greater under these pH conditions. The closer the contents of a tank are to
the neutral value of 7, the less likely that they will corrode a tank wall. Mixing nonreactive substances
to arrive at a neutral pH is a useful method to help ensure content compatibility. Corrosive substances
rapidly attack carbon steel tanks, but most plastics have excellent resistance to acids and bases.
4.3.2 Chlorides and Fluorides
When a chloride or, to a lesser extent, a fluoride solution is stored in a metal tank, the compound
will generally remove metal atoms from the tank to form soluble salts. This form of tank wall deteriora-
tion may not be uniform over tank walls. Instead, the attack may be concentrated in areas of stress
(i.e., joints, welds, corners, bends) and result in leaks in these places long before the overall strength
of a tank is noticeably reduced. For example, carbon steel, stainless steel, and aluminum deteriorate
rapidly in the presence of chlorides and fluorides. Titanium tanks have exceptional resistance to attack
from hot chloride solutions. Plastics are generally unaffected by chloride solutions.
4.3.3 Oxidation
Strongly oxidizing (electron-removing) solutions such as hypochlorides, peroxides, and per-
manganates can corrode some types of metal and nonmetallic tanks.
40
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OSWER DIR.9650.1
4.3.4 Solvent Action
Some types of nonmetallic tank and liner materials may be susceptible to "softening," dissolu-
tion, or decomposition by solvents. The relatively large spaces between the particles that form light,
soft plastics (as compared to the small spaces in metals) can allow gases and some liquids to pass
into tank walls. As the plastic absorbs solvents, the walls swell and soften. Plastic molecules can then
leave the material, resulting in contamination of tank contents and wall shrinkage and cracking. In
effect, a tank wall acts somewhat like a sponge, drawing liquid into its structure until it becomes
saturated. Continued pressure by tank contents causes the absorbed liquids to travel through the plastic
walls and enter the surrounding soil or, in the case of a plastic liner, contact the supporting tank shell.
Overall tank resistance to puncture is also diminished by softening. Periodic hardness testing of a
tank in use (Durometer, Rockwell, or Barcol hardness tests) can show if softening is occurring and
indicate if permeation (seepage) is a potential problem.
FRP depends on good bonding between the fibers and the plastic to give the composite material
the necessary mechanical strength. Solvents that cause swelling of FRP can permanently damage
the bonds to the fibers, resulting in a great loss of tank strength and subsequent tank failure. Thus,
particular resins must be used in FRP tanks that are compatible with the material stored. If no perma-
nent damage is done by solvent absorption, however, a tank can usually be "dried out" to restore
its strength.
Heavy materials such as metals and hard plastics have small pore spaces that are generally
impermeable to liquids and most gases. Pore size can be estimated from a tank material's density.
Metals, however, can be susceptible to cracking where a small surface irregularity can propagate into
a large crack in the presence of particular stored materials. Certain chemicals such as chromic acid,
aluminum chloride, nickel nitrate, potassium hydroxide, and sodium hydroxide can cause such crack-
ing in a carbon steel tank, producing early tank failure. Aluminum and its alloys, copper, brass and
bronze, are generally resistant to solvents.
4.4 Lining Tanks
The use of a tank liner material can provide added assurance of material compatibility. For exam-
ple, a liner which is resistant to all chemical substances that are used singularly or in combination
in an industrial operation can be bonded inside a metal tank. By so doing, the strength of the metal
is combined with the chemical resistance of the liner to produce a tank that is both structurally sound
and compatible with its stored contents. In a similar manner, FRP tanks can be lined with special resins
designed to resist specific chemical substances.
Underground tanks may be relined in situ or after removal from the ground. Adequate surface
preparation is necessary prior to relining. Sandblasting of metal tanks and thorough tank cleaning
are the minimum surface preparations generally required prior to relining. Tanks in poor structural
condition should not be relined.
New tanks may be purchased equipped with liners installed by their manufacturers. Liners must
be applied to the proper thickness and must be adequately tested and inspected. As discussed in
Section 4.3, selection of a tank liner depends on resistance to the presence of the four chemical
characteristics that may weaken the liner: pH extremes, chlorides and fluorides, oxidation, and solvent
action.
41
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OSWER DIR.9650.1
APPENDIX A
A-l
-------
OSWER DIR.9650.1
TITLE VI—UNDERGROUND STORAGE TANKS
UNDERGROUND STORAGE TANK REGULATION
SEC. 601. (a) The Solid Waste Disposal Act is amended by adding
the following new subtitle after subtitle H:
"Subtitle I—Regulation of Underground Storage Tanks
"DEFINITIONS AND EXEMPTIONS
42 USC 6991. «sec. 9001. For the purposes of this subtitle—
"(1) The term 'underground storage tank' means any one or
combination of tanks (including underground pipes connected
thereto) which is used to contain an accumulation of regulated
substances, and the volume of which (including the volume of
the underground pipes connected thereto) is 10 per centum or
more beneath the surface of the ground. Such term does not
include any—
"(A) farm or residential tank of 1,100 gallons or less
capacity used for storing motor fuel for noncommercial
purposes,
petroleum <<(B) tank used for storinS heating oil for consumptive use
products on the premises where stored,
"(C) septic tank,
"(D) pipeline facility (including gathering lines) regulated
under—
"(i) the Natural Gas Pipeline Safety Act of 1968 (49
U.S.C.App. 1671,etseq.),
"(ii) the Hazardous Liquid Pipeline Safety Act of 1979
(49 U.S.C. App. 2001, et seq.), or
"(iii) which is an intrastate pipeline facility regulated
under State laws comparable to the provisions of law
referred to in clause (i) or (ii) of this subparagraph,
"(E) surface impoundment, pit, pond, or lagoon,
"(F) storm water or waste water collection system,
"(G) flow-through process tank,
"(H) liquid trap or associated gathering lines directly
related to oil or gas production and gathering operations, or
"(I) storage tank situated in an underground area (such
as a basement, cellar, mineworking, drift, shaft, or tunnel)
if the storage tank is situated upon or above the surface of
the floor.
-------
98 STAT. 3278
PUBLIC LAW 98-616-NOV. 8, 1984
OSWER DIR.9650.1
42 USC 9601.
42 USC 6921.
42 USC 699la.
The term 'underground storage tank' shall not include any
pipes connected to any tank which is described in subpara-
graphs (A) through (I).
"(2) The term 'regulated substance' means —
"(A) any substance defined in section 101(14) of the Com-
prehensive Environmental Response, Compensation, and
Liability Act of 1980 (but not including any substance
regulated as a hazardous waste under subtitle C), and
(B) petroleum, including crude oil or any fraction there-
of which is liquid at standard conditions of temperature and
pressure (60 degrees Fahrenheit and 14.7 pounds per square
inch absolute).
"(3) The term 'owner' means—
"(A) in the case of an underground storage tank in use on
the date of enactment of the Hazardous and Solid Waste
Amendments of 1984, or brought into use after that date,
any person who owns an underground storage tank used for
the storage, use, or dispensing of regulated sustances, and
"(B) in the case of any underground storage tank in use
before the date of enactment of the Hazardous and Solid
Waste Amendments of 1984, but no longer in use on the
date of enactment of such Amendments, any person who
owned such tank immediately before the discontinuation of
its use.
"(4) The term 'operator' means any person in control of, or
having responsibility for, the daily operation of the under-
ground storage tank.
"(5) The term 'release' means any spilling, leaking, emitting,
discharging, escaping, leaching, or disposing from an under-
ground storage tank into ground water, surface water or subsur-
face soils.
"(6) The term 'person' has the same meaning as provided in
section 1004(15), except that such term includes a consortium, a
joint venture, and a commercial entity, and the United States
Government.
"(7) The term 'nonoperatipnal storage tank' means any under-
ground storage tank in which regulated substances will not be
deposited or from which regulated substances will not be dis-
pensed after the date of the enactment of the Hazardous and
Solid Waste Amendments of 1984.
"SBC. 9002. (a) UNnKRGROOND STORAGE TANKS.— (1) Within 18
months after the date of enactment of the Hazardous and Solid
Waste Amendments of 1984, each owner of an underground storage
tank shall notify the State or local agency or department designated
pursuant to subsection (bXl) of the existence of such tank, specifying
the age, size, type, location, and uses of such tank.
"(2XA) For each underground storage tank taken out of operation
after January 1, 1974, the owner of such tank shall, within eighteen
months after the date of enactment of the Hazardous and Solid
Waste Amendments of 1984, notify the State or local agency, or
department designated pursuant to subsection (bXl) of the existence
of such tanks (unless the owner knows the tank subsequently was
removed from the ground). The owner of a tank taken out of
operation on or before January 1, 1974, shall not be required to
notify the State or local agency under this subsection.
"(B) Notice under subparagraph (A) shall specify, to the extent
known to the owner —
-------
PUBLIC LAW 98-616—NOV. 8, 1984
OSWER DIR.9650.1
98 STAT. 3279
"(i) the date the tank was taken out of operation,
"(ii) the age of the tank on the date taken out of operation,
"(iii) the size, type and location of the tank, and
"(iv) the type and quantity of substances left stored in such
tank on the date taken out of operation.
"(3) Any owner which brings into use an underground storage
tank after the initial notification period specified under paragraph
(1), shall notify the designated State or local agency or department
within thirty days of the existence of such tank, specifying the age,
size, type, location and uses of such tank.
"(4) Paragraphs (1) through (3) of this subsection shall not apply to
tanks for which notice was given pursuant to section 103(c) of the
Comprehensive Environmental Response, Compensation, and Liabil-
ity Act Of 1980. 42 USC 9603.
"(5) Beginning thirty days after the Administrator prescribes the
form of notice pursuant to subsection (bX2) and for eighteen months
thereafter, any person who deposits regulated substances in an
underground storage tank shall reasonably notify the owner or
operator of such tank of the owner's notification requirements
pursuant to this subsection.
"(6) Beginning thirty days after the Administrator issues new
tank performance standards pursuant to section 9003(e) of this
subtitle, any person who sells a tank intended to be used as an infra.
underground storage tank shall notify the purchaser of such tank of
the owner's notification requirements pursuant to this subsection.
"(b) AGENCY DESIGNATION.—(1) Within one hundred and eighty State and local
days after the enactment of the Hazardous and Solid Waste Amend- governments.
ments of 1984, the Governors of each State shall designate the
appropriate State agency or department or local agencies or depart-
ments to receive the notifications under subsection (a) (1), (2), or (3).
"(2) Within twelve months after the date of enactment of the Public
Hazardous and Solid Waste Amendments of 1984, the Administra- information.
tor, in consultation with State and local officials designated pursu-
ant to subsection (bXl), and after notice and opportunity for public
comment, shall prescribe the form of the notice and the information
to be included in the notifications under subsection (a) (1), (2), or (3).
In prescribing the form of such notice, the Administrator shall take
into account the effect on small businesses and other owners and
operators.
"RELEASE DETECTION, PREVENTION, AND CORRECTION REGULATIONS
"SEC. 9003. (a) REGULATIONS.—The Administrator, after notice and 42 USC 699ib.
opportunity for public comment, and at least three months before
the effective dates specified in subsection (f), shall promulgate re-
lease detection, prevention, and correction regulations applicable to
all owners and operators of underground storage tanks, as may be
necessary to protect human health and the environment.
"(b) DISTINCTIONS IN REGULATIONS.—In promulgating regulations
under this section, the Administrator may distinguish between
types, classes, and ages of underground storage tanks. In making
such distinctions, the Administrator may take into consideration
factors, including, but not limited to: location of the tanks, soil and
climate conditions, uses of the tanks, history of maintenance, age of
the tanks, current industry recommended practices, national con-
sensus codes, hydrogeology, water table, size of the tanks, quantity
of regulated substances periodically deposited in or dispensed from
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OSWER DIR.9650.1
98 STAT. 3280 PUBLIC LAW 98-616—NOV. 8, 1984
the tank, the technical capability of the owners and operators, and
the compatibility of the regulated substance and the materials of
which the tank is fabricated.
"(c) REQUIREMENTS.—The regulations promulgated pursuant to
this section shall include, but need not be limited to, the following
requirements respecting all underground storage tanks—
"(1) requirements for maintaining a leak detection system, an
inventory control system together with tank testing, or a com-
parable system or method designed to identify releases in a
manner consistent with the protection of human health and the
environment;
"(2) requirements for maintaining records of any monitoring
or leak detection system or inventory control system or tank
testing or comparable system;
"(3) requirements for reporting of releases and corrective
action taken in response to a release from an underground
storage tank;
"(4) requirements for taking corrective action in response to a
release from an underground storage tank; and
"(5) requirements for the closure of tanks to prevent future
releases of regulated substances into the environment.
"(d) FINANCIAL RESPONSIBILITY.—<1) As he deems necessary or
desirable, the Administrator shall promulgate regulations contain-
ing requirements for maintaining evidence of financial responsibil-
ity as he deems necessary and desirable f->r taking corrective action
and compensating third parties for bodily injury and property
damage caused by sudden and nonsudden accidental releases arising
from operating an underground storage>tank.
"(2) Financial responsibility required by this subsection may be
established in accordance with regulations promulgated by the
Administrator by any one, or any combination, of the following:
insurance, guarantee, surety bond, letter of credit, or qualification
as a self-insurer. In promulgating requirements under this subsec-
tion, the Administrator is authorized to specify policy or other
contractual terms, conditions, or defenses which are necessary or
are unacceptable in establishing such evidence of financial responsi-
bility in order to effectuate the purposes of this subtitle.
Courts. U.S. "(3) In any case where the owner or operator is in bankruptcy,
reorganization, or arrangement pursuant to the Federal Bankruptcy
Code or where with reasonable diligence jurisdiction in any State
court of the Federal Courts cannot be obtained over an owner or
operator likely to be solvent at the time of judgment, any claim
arising from conduct for which evidence of financial responsibility
must be provided under this subsection may be asserted directly
against the guarantor providing such evidence of financial responsi-
bility. In the case of any action pursuant to this paragraph such
guarantor shall be entitled to invoke all rights and defenses which
would have been available to the owner or operator if any action
had been brought against the owner or operator by the claimant and
which would have been available to the guarantor if an action had
been brought against the guarantor by the owner or operator.
"(4) The total liability of any guarantor shall be limited to the
aggregate amount which the guarantor has provided as evidence of
financial responsibility to the owner or operator under this section.
Nothing in this subsection shall be construed to limit any other
State or Federal statutory, contractual or common law liability of a
guarantor to its owner or operator including, but not limited to, the
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PUBLIC LAW 98-616-NOV. 8, 1984 98 STA°FWMIR-9650-1
liability of such guarantor for bad faith either in negotiating or in
(ailing to negotiate the settlement of any claim. Nothing in this
subsection shall be construed to diminish the liability of any person
under section 107 or 111 of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 or other 42 USC 9607,
applicable law. 9611-
"(5) For the purpose of this subsection, the term 'guarantor'
means any person, other than the owner or operator, who provides
evidence of financial responsibility for an owner or operator under
this subsection.
"(e) NEW TANK PERFORMANCE STANDARDS.—The Administrator
shall, not later than three months prior to the effective date speci-
fied in subsection (f), issue performance standards for underground
storage tanks brought into use on or after the effective date of such
standards. The performance standards for new underground storage
tanks shall include, but need not be limited to, design, construction,
installation, release detection, and compatibility standards.
"(f) EFFECTIVE DATES.—(1) Regulations issued pursuant to subsec-
tion (c) and (d) of this section, and standards issued pursuant to
subsection (e) of this section, for underground storage tanks contain-
ing regulated substances defined in section 9001(2XB) (petroleum,
including crude oil or any fraction thereof which is liquid at stand-
ard conditions of temperature and pressure) shall be effective not
later than thirty months after the date of enactment of the Hazard-
ous and Solid Waste Amendments of 1984.
"(2) Standards issued pursuant to subsection (e) of this section
(entitled 'New Tank Performance Standards') for underground
storage tanks containing regulated substances defined in section
900K2XA) shall be effective not later than thirty-six months after
the date of enactment of the Hazardous and Solid Waste Amend-
ments of 1984.
"(3) Regulations issued pursuant to subsection (c) of this section
(entitled 'Requirements') and standards issued pursuant to subsec-
tion (d) of this section (entitled 'Financial Responsibility') for un-
derground storage tanks containing regulated substances defined in
section 900K2XA) shall be effective not later than forty-eight months
after the date of enactment of the Hazardous and Solid Waste
Amendments of 1984.
"(g) INTERIM PROHIBITION.—(1) Until the effective date of the
standards promulgated by the Administrator under subsection (e)
and after one hundred and eighty days after the date of the enact-
ment of the Hazardous and Solid Waste Amendments of 1984, no
person may install an underground storage tank for the purpose of
storing regulated substances unless such tank (whether of single or
double wall construction)—
"(A) will prevent releases due to corrosion or structural fail-
ure for the operational life of the tank;
"(B) is cathodically protected against corrosion, constructed of
noncorrosive material, steel clad with a noncorrosive material,
or designed in a manner to prevent the release or threatened
release of any stored substance; and
"(C) the material used in the construction or lining of the
tank is compatible with the substance to be stored.
"(2) Notwithstanding paragraph (1), if soil tests conducted in
accordance with ASTM Standard G57-78, or another standard ap-
proved by the Administrator, show that soil resistivity in an instal-
lation location is 12,000 ohm/cm or more (unless a more stringent
51-139 0-85—2 (670)
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OSWER DIR.9650.1
98 STAT. 3282 PUBLIC LAW 98-616—NOV. 8, 1984
standard is prescribed by the Administrator by rule), a storage tank
without corrosion protection may be installed in that location
during the period referred to in paragraph (1).
"APPROVAL OF STATE PROGRAMS
42 USC 699ic. "Sec. 9004. (a) ELEMENTS OP STATE PROGRAM.—Beginning 30
months after the date of enactment of the Hazardous and Solid
Waste Amendments of 1984, any State may, submit an underground
storage tank release detection, prevention, and correction program
for review and approval by the Administrator. The program may
cover tanks used to store regulated substances referred to in
9001(2) (A) or (B) or both. A State program may be approved by the
Administrator under this section only if the State demonstrates that
the State program includes the following requirements and
standards and provides for adequate enforcement of compliance with
such requirements and standards—
"(1) requirements for maintaining a leak detection system, an
inventory control system together with tank testing, or a com-
parable system or method designed to identify releases in a
manner consistent with the protection of human health and the
environment;
"(2) requirements for maintaining records of any monitoring
or leak detection system or inventory control system or tank
testing system;
"(3) requirements for reporting of any releases and corrective
action taken in response to a release from an underground
storage tank;
"(4) requirements for taking corrective action in response to a
release from an underground storage tank;
"(5) requirements for the closure of tanks to prevent future
releases of regulated substances into the environment;
"(6) requirements for maintaining evidence of financial re-
sponsibility for taking corrective action and compensating third
parties for bodily injury and property damage caused by sudden
and nonsudden accidental releases arising from operating an
underground storage tank;
"(7) standards of performance for new underground storage
tanks; and
"(8) requirements—
"(A) for notifying the appropriate State agency or depart-
ment (or local agency or department) designated according
to section 9002(bXD of the existence of any operational or
non-operational underground storage tank; and
"(B) for providing the information required on the form
issued pursuant to section 9002(bX2).
"(b) FEDERAL STANDARDS.—(1) A State program submitted under
this section may be approved only if the requirements under para-
graphs (1) through (7) of subsection (a) are no less stringent than the
corresponding requirements standards promulgated by the Adminis-
trator pursuant to section 9003(a).
"(2XA) A State program may be approved without regard to
whether or not the requirements referred to in paragraphs (1), (2),
(3), and (5) of subsection (a) are less stringent than the corresponding
standards under section 9003(a) during the one;year period com-
mencing on the date of promulgation of regulations under section
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PUBLIC LAW 98-616—NOV. 8, 1984
OSWER DIR.9650.1
98 STAT. 3283
9003(a) if State regulatory action but no State legislative action is
required in order to adopt a State program.
(B) If such State legislative action is required, the State program
may be approved without regard to whether or not the requirements
referred to in paragraphs (1), (2), (3), and (5) of subsection (a) are less
stringent than the corresponding standards under section 9003(a)
during the two-year period commencing on the date of promulgation
of regulations under section 9003(a) (and during an additional one-
year period after such legislative action if regulations are required
to be promulgated by the State pursuant to such legislative action).
"(c) FINANCIAL. RESPONSIBILITY.—(1) Corrective action and compen-
sation programs financed by fees on tank owners and operators and
administered by State or local agencies or departments may be
submitted for approval under subsection (aX6) as evidence of finan-
cial responsibility.
"(2) Financial responsibility required by this subsection may be
established in accordance with regulations promulgated by the Ad-
ministrator by any one, or any combination, of the following: insur-
ance, guarantee, surety bond, letter of credit, or qualification as a
self-insurer. In promulgating requirements under this subsection,
the Administrator is authorized to specify policy or other contrac-
tual terms, conditions, or defenses which are necessary or are
unacceptable in establishing such evidence of financial responsibil-
ity in order to effectuate the purposes of this subtitle.
"(3) In any case where the owner or operator is in bankruptcy, Claims.
reorganization, or arrangement pursuant to the Federal Bankruptcy
Code or where with reasonable diligence jurisdiction in any State
court of the Federal courts cannot be obtained over an owner or
operator likely to be solvent at the time of judgment, any claim
arising from conduct for which evidence of financial responsibility
must be provided under this subsection may be asserted directly
against the guarantor providing such evidence of financial responsi-
bility. In the case of any action pursuant to this paragraph such
guarantor shall be entitled to invoke all rights and defenses which
would have been available to the owner or operator if any action
had been brought against the owner or operator by the claimant and
which would have been available to the guarantor if an action had
been brought against the guarantor by the owner or operator.
"(4) The total liability of any guarantor shall be limited to the
aggregate amount which the guarantor has provided as evidence of
financial responsibility to the owner or operator under this section.
Nothing in this subsection shall be construed to limit any other
State or Federal statutory, contractual or common law liability of a
guarantor to its owner or operator including, but not limited to, the
liability of such guarantor for bad faith either in negotiating or in
failing to negotiate the settlement of any claim. Nothing in this
subsection shall be construed to diminish the liability of any person
under section 107 or 111 of the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 or other applica-
ble law.
"(5) For the purpose of this subsection, the term 'guarantor'
means any person, other than the owner or operator, who provides
evidence of financial responsibility for an owner or operator under
this subsection.
"(d) EPA DETERMINATION.—(1) Within one hundred and eighty
days of the date of receipt of a proposed State program, the Adminis-
trator shall, after notice and opportunity for public comment, make
State and local
governments.
42 USC 9607.
9611.
Public
information.
-------
98 STAT. 3284
PUBLIC LAW 98-616—NOV. 8, 1984
OSWER DIR.9650.1
State and local
governments.
42 USC 699 Id.
Records.
Reports.
a determination whether the State's program complies with the
provisions of this section and provides for adequate enforcement of
compliance with the requirements and standards adopted pursuant
to this section.
"(2) If the Administrator determines that a State program com-
plies with the provisions of this section and provides for adequate
enforcement of compliance with the requirements and standards
adopted pursuant to this section, he shall approve the State program
in lieu of the Federal program and the State shall have primary
enforcement responsibility with respect to requirements of its
program.
"(e) WITHDRAWAL OF AUTHORIZATION.—Whenever the Administra-
tor determines after public hearing that a State is not administering
and enforcing a program authorized under this subtitle in accord-
ance with the provisions of this section, he shall so notify the State.
If appropriate action is not taken within a reasonable time, not to
exceed one hundred and twenty days after such notification, the
Administrator shall withdraw approval of such program and rees-
tablish the Federal program pursuant to this subtitle.
"INSPECTIONS, MONITORING, AND TESTING
"Sec. 9005. (a) FURNISHING INFORMATION.—For the purposes of
developing or assisting in the development of any regulation, con-
ducting any study, or enforcing the provisions of this subtitle, any
owner or operator of an underground storage tank (or any tank
subject to study under section 9009 that is used for storing regulated
substances) shall, upon request of any officer, employee or repre-
sentative of the Environmental Protection Agency, duly designated
by the Administrator, or upon request of any duly designated offi-
cer, employee, or representative of a State with an approved pro-
gram, furnish information relating to such tanks, their associated
equipment, their contents, conduct monitoring or testing, and
permit such officer at all reasonable times to have access to, and to
copy all records relating to such tanks. For the purposes of develop-
ing or assisting in the development of any regulation, conducting
any study, or enforcing the provisions of this subtitle, such officers,
employees, or representatives are authorized—
"(1) to enter at reasonable times any establishment or other
place where an underground storage tank is located;
"(2) to inspect and obtain samples from any person of any
regulated substances contained in such tank; and
(3) to conduct monitoring or testing of the tanks, associated
equipment, contents, or surrounding soils, air, surface water or
ground water.
Each such inspection shall be commenced and completed with rea-
sonable promptness.
"(b) CONFIDENTIALITY.—(1) Any records, reports, or information
obtained from any persons under this section shall be available to
the public, except that upon a showing satisfactory to the Adminis-
trator (or the State, as the case may be) by any person that records,
reports, or information, or a particular part thereof, to which the
Administrator (or the State, as the case may be) or any officer,
employee, or representative thereof has access under this section if
made public, would divulge information entitled to protection under
section 1905 of title 18 of the United States Code, such information
or particular portion thereof shall be considered confidential in
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PUBLIC LAW 98-616—NOV. 8, 1984
OSWER DIR.9650.1
98 STAT. 3285
accordance with the purposes of that section, except that such
record, report, document, or information may be disclosed to other
officers, employees, or authorized representatives of the United
States concerned with carrying out this Act, or when relevent in any
proceeding under this Act.
"(2) Any person not subject to the provisions of section 1905 of Crimes and
title 18 of the United States Code who knowingly and willfully misdemeanor*.
divulges or discloses any information entitled to protection under
this subsection shall, upon conviction, be subject to a fine of not
more than $5,000 or to imprisonment not to exceed one year, or
both.
"(3) In submitting data under this subtitle, a person required to
provide such data may—
"(A) designate the data which such person believes is entitled
to protection under this subsection, and
"(B) submit such designated data separately from other data
submitted under this subtitle.
A designation under this paragraph shall be made in writing and in
such manner as the Administrator may prescribe.
"(4) Notwithstanding any limitation contained in this section or
any other provision of law, all information reported to, or otherwise
obtained, by the Administrator (or any representative of the Admin-
istrator) under this Act shall be made available, upon written
request of any duly authorized committee of the Congress, to such
committee (including records, reports, or information obtained by
representatives of the Evironmental Protection Agency).
"FEDERAL ENFORCEMENT
"SEC. 9006. (a) COMPLIANCE ORDERS.—(1) Except as provided in
paragraph (2), whenever on the basis of any information, the Admin-
istrator determines that any person is in violation of any
requirement of this subtitle, the Administrator may issue an order
requiring compliance within a reasonable specified time period or
the Administrator may commence a civil action in the United States
district court in which the violation occurred for appropriate relief,
including a temporary or permanent injunction.
"(2) In the case of a violation of any requirement of this subtitle
where such violation occurs in a State with a program approved
under section 9004, the Administrator shall give notice to the State
in which such violation has occurred prior to issuing an order or
commencing a civil action under this section.
"(3) If a violator fails to comply with an order under this subsec-
tion within the time specified in the order, he shall be liable for a
civil penalty of not more than $25,000 for each day of continued
noncompliance.
"(b) PROCEDURE.—Any order issued under this section shall
become final unless, no later than thirty days after the order is
served, the person or persons named therein request a public hear-
ing. Upon such request the Administrator shall promptly conduct a Hearing.
public hearing. In connection with any proceeding under this section
the Administrator may issue subpoenas for the attendance and
testimony of witnesses and the production of relevant papers, books,
and documents, and may promulgate rules for discovery procedures.
"(c) CONTENTS OF ORDER.—Any order issued under 'this section
shall state with reasonable specificity the nature of the violation,
specify a reasonable time for compliance, and assess a penalty, if
Crimes and
misdemeanors.
42 USC 699 le.
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98 STAT. 3286
PUBLIC LAW 98-616—NOV. 8, 1984 OSWER
any, which the Administrator determines is reasonable taking into
account the seriousness of the violation and any good faith efforts to
comply with the applicable requirements.
Crimes and "(d) CTVTL PENALTIES.—(1) Any owner who knowingly fails to
misdemeanors. notify or submits false information pursuant to section 9002(a) shall
be subject to a civil penalty not to exceed $10,000 for each tank for
which notification is not given or false information is submitted.
"(2) Any owner or operator of an underground storage tank who
fails to comply with—
"(A) any requirement or standard promulgated by the Admin-
istrator under section 9003;
"(B) any requirement or standard of a State program ap-
proved pursuant to section 9004; or
"(C) the provisions of section 9003(g) (entitled 'Interim
Prohibition')
shall be subject to a civil penalty not to exceed $10,000 for each tank
for each day of violation.
"FEDERAL FACILITIES
42USC699if. "SEC. 9007. (a) APPLICATION OF SUBTITLE.—Each department,
agency, and instrumentality of the executive, legislative, and judi-
cial branches of the Federal Government having jurisdiction over
any underground storage tank shall be subject to and comply with
all Federal, State, interstate, and local requirements, applicable to
such tank, both substantive and procedural, in the same manner,
and to the same extent, as any other person is subject to such
requirements, including payment of reasonable service charges. Nei-
ther the United States, nor any agent, employee, or officer thereof,
shall be immune or exempt from any process or sanction of any
State or Federal court with respect to the enforcement of any such
injunctive relief.
"(b) PRESIDENTIAL EXEMPTION.—The President may exempt any
underground storage tanks of any department, agency, or instru-
mentality in the executive branch from compliance with such a
requirement if he determines it to be in the paramount interest of
the United States to do so. No such exemption shall be granted due
to lack of appropriation nnlrea the President shall have specifically
requested such appropriation as a part of the budgetary process and
the Congress shall have failed to make available such requested
appropriations. Any exemption shall be for a period not in excess of
one year, but additional exemptions may be granted for periods not
to exceed one year upon the President's making a new determina-
tion. The President shall report each January to the Congress all
exemptions from the requirements of this section granted during the
preceding calendar year, together with his reason for granting each
such exemption.
"STATE AUTHORITY
42 USC 699ig. "SEC. 9008. Nothing in this subtitle shall preclude or deny any
right of any State or political subdivision thereof to adopt or enforce
any regulation, requirement or standard of performance respecting
underground storage tanks that is more stringent than a regulation,
requirement, or standard of performance in effect under this
subtitle.
President of U.S.
Report
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OSWER DIR.9650.1
APPENDIX B
B-l
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OSWER DIR.9650.1
29413 Federal Register / Vol. 51. No. 10" / Wednesday, June 4, 1986 / Rules and Regulations
ENVIRONMENTAL PROTECTION
AGENCY
40 CrR Part 280
[FRL 2928-9]
Hazardous Waste; Interpretive Rule on
the Interim Prohibition Against
Installation of Unprotected
Underground Storage Tanks
AGENCY. Environments! Protection
Agency.
ACTVON: Interpretive rule.
: New Subtitle I of une
Reso-jrce Conservation and Recovery
Act fRCRA}, as amended, provides for
the regulation of underground storage
tanks. Section 9003(gj of Subtitle 1
establishes interim requirements for
underground storage tanks that are
instated between Maj 7, 1985 and the
effective date of new tank standards
required to be promulgated by EPA
under section 9003(e). This notice sets
forth EPA's interpretation of Section
FOR FURTHER INFORMATION CONTACT:
Pamela Harris, (202; 332-4814. or Steven
Way. (202) 475-9328: or the RCRA/
S'opf rf^nd Hotline at ,SOO) 424-9346
f»o'.l free or (202) 382-300C in
U&ihington, DC.
SUPP'-EWENTAflY INFORMATION:
I. Introduction: The Hazardous and Solid
Waste Amendments of 1984
C~ November 8, 1984, the President
signt d into law the Hazardous and Solid
Waste Amendments of 1984, Public Law
98-616. These Amendments extend and
strengthen the provisions of the Solid
Waste Disposal Act of 1970 as amended
by RCRA, A major portion of this new
legislation. Subtitle I. provides for the
development and implementation of a
regulatory program for underground
storage tanks used to contain regulated
substances, which include petroleum
and substances defined as hazardous
substances under section 101(14) of the
Comprehensive Environmental
Response, Compensation and Liability
Act(CERCLA).'
1 "Underground storage tank" is denned under
RCRA Subtitle I. section 9001(1] at any one or
combination of tanks (including underground pipes
conaecled thereto) which is used to contain an
accumulation of regulated substances, and the
voluse of which (including the volume of the
underground pipes connected thereto) U10 percent
or catxr beneath the surface of the ground. Such
tern does not Include any—
(A) Farm or residential tank of 1.100 gallons or
lets capacity used for storing motor fuel for
noncommercial purposes,
(B) Tank used for storing heating oil for
aptlve use on the premises when stored.
Among the provisions of new Subtitle
I. section 9003 requires EPA to
promulgate regulations pertaining to the
detection, prevention, and correction of
releases from underground storage tanks
as may be necessary to protect human
health and the environment.8 Section
9003(c) sets forth minimum requirements
that must be promulgated for all
underground storage tanks and section
9003(e) sets forth additional
requirements that must be promulgated
for new underground storage tanks.
Regulations under both sections 9003 (c)
and (e) for tanks containing petroleum
products are to be effective by May 8,
1987. With respect to tanks containing
hazardous substances, regulations under
section 9003(e' for new tanks are to be
effective by November 8,198? and
regulations under section 9003[c) for
existing tanks are to be effective by
November 8, 1988.
Until new tank standards promulgated
under section 9003(e) become effective,
section 9003(g)(l) establishes interim
requirements for any tank installed on
or after May 7,1985. That section
provides as follows:
[N]o person may install an underground
storage tank for the purpose of storing
regulated substances unless such tank
(whether of single or double walled
ccri'i. uciion)—
(.".' will prevent releases due ;n c&rrosjon
or structural failure for the operoiional life of
the tawc;
(C) Septic tank.
(D! Pipeline facility (including gatcenng lines)
regulated under-
(i) The Natural Gas Pipeline Safety Act of 1968.
(49 U.S.C. App. 1871. et »eq J.
(11) The Hazardous Liquid Pipeline Safety Act of
1979 (49 US.C. App. 2001 et seq.J. or
(ui) Which is an sntrastate pipeline facility
regulated under State laws comparable to the
provisions of law referred to m clause (i) or (u) of
this subparagraph:
(E) Surface impoundment pit. pond or lagoon.
(F) Storm water or waste water collection system,
(G) Flow-through process tank.
(H) Liquid trap or associated gathering line*
directly related to oil or gas production and
gathering operation*, or
(I) Storage tank situated in an underground area
(such a* a basement, cellar, nuneworxing, drift
•haft or tunnel) if the storage tank is situated upon
or above the surface of the floor.
"Regulated substancei" are defined under RCRA
Subtitle!, section 9001(2) as:
(A) Any substance denned in section 101(14) of
the Comprehensive Environmental Response,
Compensation, and liability Act of 1380 (but not
including any substance regulated as a hazardous
waste under Subtitle C), and
(B) Petroleum, including crude oil or any fraction
thereof which is liquid at standard conditions of
temperature and pressure (80 degrees Fahrenheit
and 14.7 pound* per square inch absolute).
* "Release" is denned under RCRA Subtitle L
section 9001(5) a* any spilling, leaking, emitting.
discharging, escaping, leaching, or disposing from
an underground storage tank into ground water.
surface water or subsurface soils.
(B) is cathodically protected against
corrosion, constructed of noncorrosive
material, stee! clad with a noncorrosive
material, or designed in a manner to prevent
the release or threatened reiesse of any
stored substance- and
(C) the matenal used in tne construction or
lin:ng of the tank IB compatible with the
substance to be stored.
As a limited exception, section
9003(g)(2) allows the installation of
tanks without corrosion protection ir
soil with a resistivity of 12.000 ohm-cm
or more. Under that provision, soii tests
must be conducted in accordance witfi
Amencan Society for Testing and
Materials (ASTM) Standard G57-78.
II. Purpose of the Interpretive Rule
An interpretive role is a statement
issued by an agency to advise -_r.e public
of the agency's construction of the
statutes and rules that u administers An
interpretive rule simply construes the
language of the statute or regulation and
does not impose additional obligations.
Such rules are exempt from the notice
and comment requirements of the
Administrative Procedures Act, 5 U.S C.
553{bHAj [1982). A substantive rule.
such as the new tank standards
authorized by sector. 90C3(e). is a rule
that is issued by an isgency parsuan' to
statutory authority that implements the
stat. te. EPA intends this notice to be an
interpretive rale, not a substantive nils.
Section 90G3(g] establishes statutory
requirements that took effect on May 7,
1985 without pnor action on the pan of
EPA. Several of the requirements set
forth under section 9003 [g] are in the
form of performance standards. EPA
believes that the interpretive rule
clarifies obligations of the regulated
community in complying with the
interim prohibition. The rule also puts
the regulated community on notice of
the circumstances under which the
Agency will proceed with enforcement
action for noncompliance.
m. Other Related EPA Activities
On July 15,1985, EPA codified the
statutory language of section 9003(g) in
its regulations at 40 CFR 280.2.
EPA is oreparing a guidance
document that is available in draft form
in the Regional Offices. This document
discusses methods and technologies for
preventing releases from tanks due to
corrosion, structural failure, or the
storage of materials that are
incompatible with the tanks'
construction or lining. This guidance will
assist tank users in determining
effective approaches to meet the
performance standards in section
9003(g).
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OSWER DIR.9650.1
Federal Register / VoL 51, No. 107 / Wednesday. June 4, 1986 / Rules and Regulations 20411
TV. Legislative History of Section 90C3(g)
Mdny of the storage tank provisions
now contained in Subtitle I, including
section 9003(g), had their origins ir a bill
introduced by Senator Durenberger on
February 29,1964 as an amendment to
the Safe Drinking Water Act, 130 Cong.
Rec. S2026 (Feb. 29,1984). Among the^e
provisions was a requirement that EPA
promulgate new tank standards within
nine months of the date of enactment of
the proposed amendments. Such
standards were to include ? prohibition
on bare steel tanks. Id. at ,.2028. The
provisions established an oxceprion
from the bare stee! tank ban "where the
Administrator finds tftore is minimal
danger of corrosion." Id. In describing
that provision. Senator Durenberger
stuted that "installation of common but
less adequate tanks—those made of
bare steel—would be prohibited -unless
the hydrcgeology of the area is such that
there is a minimal danger of corrosion."
Id. at S2C27.
On July 25,1984. Senator Durenberger
offered a modified version of his storage
tank provisions as an amendment to
RCRA. 130 Cong. Rec. S91-4 (July 25.
1984). This amendment was passed by
the Senate. Id. at S9201. In this modified
version, the deadline for—new tank
standards was extended and the bare
stee! ban was convert..d into an interim
requirement that new tanks be installed
in accordance with enforced national
consensus code." This requirement was
to go into effect nir.aiy days after the bill
was passed and remain effective until
EPA promulgated new tank standards.
Id. at S9183-S4.
On the House of Representatives side,
amendments t. RCRA were passed but
did not contain provisions for the
regulation of underground storage tanks.
130 Cong. Rec, H9184 (November 3,
1983). On August 10,1984, however, the
House passe 1 an underground storage
tank bill as an amendment to CERCLA.
130 Cong. Rec. H893& H9027 (August 10,
1984). The House bill contained an
interim prohibition that provided as
follows:
Until the effective date of the regulations
promulgated by the Administrator under
subsection (a) and after 180 days after the
date of the enactment of this title, no person
may install or begin using an underground
storage tank for the purpose of storing
hazardous substances unless such tank, of
either single or double wall construction, is
cathodicaily protected against corrosion,
constructed of noncorroswe material, steel
clad with a noncorrosive .-aateriai which
would prevent corrosion for the operational
life of the tank, or contained in a manner
designed to prevent the release or threatened
release . the Senate amendment which
prohibits installation of bare Sisai tanks
except m states that enforce a aanonai
consensus code.
130 Cong. Rec. 11139 (Oct. 3.1384).
The bill, as reported by the
Conference Committee, ultimately
passed both houses and was signed by
the President on November 8,1964.
The legislative history of section
90O3(g) reveals that as originally
introduced in the Senate, the section
was aimed at preventing toe installation
of steel tank systems without corrosion
protection. Ultimately, however, section
9003(g) was expanded not only to
prohibit installation of bare steel tanks.
but also to include requirements
pertaining to the structural integrity of
all newly installed tanks and the
compatibility of the substances stored
with the materials used in the
construction and lining of sues tanks.
V. EPA's Interpretation of Section
9003(g)
EPA reviewed the statutory language
of section 9003(g) and its legislative
history. Based upon this review, EPA's
conclusions are set forth below.
Section 9003(g) (codified as 40 CFR
280.2) establishes three requirements
that must be satisfied by all
underground storage tanks (including
underground pipes connected to th^
ta-.ks) installed between May 7,19fl5
and the effective date of new tank
standards promulgated under RCRA
sectior 9003(e), with the excep'ior. of
tanks qualifying for the exemption from
corrosion protection requirements untie•
section 9003(g){2). Th^re requirements
are: (1) That the tank and underground
piping be designed, constructed, ar.J
installed to prevent releases due to
corrosion "or the operit'onal life of the
tank and the pipir.x !2i 'hat the tank and
underground piping be designed.
constructed, and installed to prevent
releases due to structural failure for the
operational life of the tank and the
piping; and (3) that the materials csed m
the construction or lirjng of the tank and
its underground piping be compatible
with the substance to be stored in the
tank.
The first two of the above
requirements are established by section
9003(g](l)(A), which provides that tarJts
must "prevent releases due to corrosion
or structural failure for the opera 'Jon a \
life of the tank." The third requirement
is established by section 9X)3ig;(T,(C;.
In addition, section 90831"gJflJJB) s«!s
forth .minimum requirements for tank
design and construction. Under section
9C03(g){l)(3], tanks must be either
cathodicaily protected against corrosion
constructed of ncncorrosive material.
steel clad with a norjcorrosive maters!
or designed in a manner to prevent the
release or threatened release of srsy
stored substance.
In addition to cathodicaily protected
tanks and tanks constructed or clad
with non-corrosive materials, section
9003(g)(lJ(B) would permit the use of
other types of tanks and protective
measures if they are "designed in a
manner to prevent the release or
threatened release of any stored
substance." Interested parties may
consult with EPA on a case-by-case
basis concerning the effectiver.ess of
particular technologies for preventing
releases.
There are several examples of tanks
that do not satisfy the requirement oi
section 9003(gj(l)(A) that they prevent
releases due to corrosion for tha
operational life of the tar.x. A steei tank
whose only corrosion protection is a
coating of noncorrcsive materials that is
applied in such a way that it will not
prevent releases due to corrosion for the
operational life of the tank is not
adequate. Similarly, a cathodicaily
protected tank whose cathodic
protection is not designed to prevent
releases for the operational life of tie
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OSWER DIR.9650.1
20420 Federal Register / Vol. 51, No. 107 / Wednesday, June 4. 1986 / Rules and Regulations
tank will not be deemed to have
satisfied this requirement.
Paint and asphalt coatings are not
adequate for cathodic protection.
Asphalt paints are soluble in a number
of regulated substances that are
normally stored in tanks, including
solvents and hydrocarbons, such as
gasoline. Applications of both asphalt
paints and lead paints are thin, easily
damaged during installation and easily
worn away during use. They do not
provide a complete seal for the tank.
such paint or asphalt coatings do not
provide corrosion resistance for the
operational life of the tank and,
therefore, do not comply with the
interim prohibition.
Tanks that satisfy the requirement of
section 9003(g)(l)(A) to prevent releases
due to corrosion must still satisfy the
requirements that they prevent releases
due to "structural failure" and that the
materials used in the construction of the
tank be compatible with the substances
to be stored. For example, a tank
constructed of noncorrosive material
that is subject to structural failure
because of its design or installation
would not satisfy the requirements of
section 9003(g)(l). S.;nilarly, a tank
whose construction materials are not
compatible with the product to be stored
would not satisfy the requirements of
section 90C3(gj(l) because, although it
satisfies the corrosion protection
requirement oflection 9C03(g)(l)(A], it
does not satisfy thr compatibility
requirement of section 9003(g)(l)(C).
Section 9003(g){l) provides that "no
person may install an underground
storage tank" unless such tank satisfies
the requirements of sections 9003(g](l)
(A), (B). and (C). EPA interprets the term
"no person may install an underground
storage tank" to encompass any persons
responsible for having a tank installed.
including among others owners,
operators and installers. EPA also
interprets section 9003(g) as applying to
all new installations, including
installation of previously used tanks and
to any new installation of underground
piping associated with underground
tanks subject to the prohibition. When
the new installation is only piping, only
the new piping would be subject to the
standards in section 9003(g).
With respect to the exemption from
corrosion protection requirements
provided by section 9003(gj{2), EPA
interprets this provision as permitting
the installation of a tank without
corrosion protection if a person, prior to
installation, demonstrates by means of
soil testing conducted in accordance
with ASTM Standard G57-58 that the
soil at the location where the tank is to
be installed does not have a resistivity
of less than 12,000 ohm-cm.
A tank exempted from corrosion
protection requirements under this
section, however, must stiil satisfy the
requirement that the tank be designed,
constructed, and installed to prevent
releases due to the structural failure of
the tank and that the materials used in
the construction or lining of the tank be
compatible with the substances to be
stored in the tank. Thus, for example, a
steel tank without any type of corrosion
protection may be installed at a location
where the soil continues to have a
resistivity of 12,000 ohm-cm during the
operational life of the tank. However, if
the tank is constructed or installed so
that it suffers structural failure or is not
compatible with the stored product and
releases its contents, the tank would not
be in compliance with section S003(g).
VI. Summary -if Supporting Analyses
;. Executive Order 12251
Executive Order 12291 [46 FR13193.
February 9,1981] requires that a
regulatory agency determine whether a
new regulation will be "major"
regulation and, if so, that a Regulatory
Impact Analysis be conducted. A major
rule is defined as regulanon which is
likely to result in:
(1) An annual effect on the economy
of $100 million or more:
(2) A major increase ia costs or prices
for consumers, individual industries.
Federal, State, and local government
agencies, or geographic regions;
(3) Significant adverse effects on
competition, employment, investment.
productivity, innovation, or on the
ability of United States-based
enterprises to compete with foreign-
based enterprises in domestic or export
markets.
This rule does not have any of the
impacts listed above. The Agency did
conduct an economic impact analysis of
the interim prohibition as part of the
Hazardous Waste Management System:
Final Codification Rule published in the
Federal Register July 15.1S85. The
Regulatory Impact Analysis concludes
that upper bound cost estimates for the
Interim Prohibition are under S10 million
per year.
The interpretive rule has been
submitted to the Office of Management
and Budget (OMB) for review as
required by Executive Order 12291.
2. Regulatory Flexibility Act
Pursuant to the Regiilatory Flexibility
Act, 5 U.S.C. 601 et set]., whenever an
agency publishes a general notice of
rulemaking for any proposed or final
rule, it must prepare and make available
for public comment a regulatory
flexibility analysis that describes the
impact of the rids on small entities ','. e.,
small businesses, small organizations.
small governmental Jurisdictions). Th«
Administrator may certify, however.
that the rule will not have a significant
economic impact on a substantial
number of small entities.
The Regulatory Impact Analysis for
the Final Codification Rule also
addr ;sses the impact of the Interim
Proruoition on small entities and
concludes that the Interim Prohibition
will not have a significant economic
impact on a substantial number of small
entities. This interpretive rale does not.
therefore, require a regulatory flexibility
analysis.
Dated: May 21.1986.
Lee M. Thonuu,
Administrator.
fFR Doc. 80-12002 Filed 6-3-36; 8:45 am)
MU.UM CODE (5«»-«0-M
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OSWER DIR.9650.1
APPENDIX C
C-l
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OSWER DIR.9650.1
APPENDIX C
STATE UNDERGROUND STORAGE CONTACTS
Alabama (EPA Form)
Alabama Department of Environmental Management
Groundwater Section/Water Division
1751 Federal Drive
Montgomery, Alabama 36130
(205) 671-7700
Alaska (EPA Form)
Department of Environmental Conservation
Pouch 0
Juneau, Alaska 99811
(907) 465-2653
American Samoa (EPA Form)
Executive Secretary
Environmental Quality Commission
Office of the Governor
American Samoan Government
Pago Pago, American Samoa 96799
Attn: UST Notification
Arizona (EPA Form)
Attn: UST Coordinator
Arizona Department of Health Services
Environmental Health Services
2005 North Central
Phoenix, Arizona 85004
(602) 257-2300
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Arkansas (EPA Form)
Arkansas Department of Pollution Control and Ecology
POB 9583
Little Rock, Arkansas 72219
(501) 562-7444
California (State Form)
Ed Anton
California Water Resources Control Board
POB 100
Sacramento, California 95801
(916) 445-9552
Colorado (EPA Form)
Kenneth Mesch, Section Chief
Colorado Department of Health
Waste Management Division
Underground Tank Program
4210 East llth Avenue
Denver, Colorado 80220
(303) 320-8333, Ext. 4364
Connecticut (State Form)
Hazardous Materials Management Unit
Department of Environmental Protection
State Office Building
165 Capitol Avenue
Hartford, Connecticut 06106
(203) 566-3437
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Delaware (State Form)
Division of Air and Waste Management
Department of Natural Resources and Environmental Control
POB 1401
89 Kings Highway
Dover, Delaware 19903
(302) 736-5409
District of Columbia (EPA Form)
Department of Consumer and Regulatory Affairs
Pesticides and Hazardous Waste Management Branch
Room 114
5010 Overlook Avenue, S.W.
Washington, D.C. 20032
Attn: UST Notification Form
(202) 767-7370
Florida .(State Form)
Florida Department of Environmental Regulation
Solid Waste Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
(904) 487-4398
Georgia (EPA Form)
Georgia Department of Natural Resources
Environmental Protection Division
Underground Storage Tank. Program
3420 Norman Berry Drive
Hapeville, Georgia 30354
(404) 656-3500
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Guam (State Form)
James B. Branch, Administrator
Guam Environmental Protection Agency
FOB 2999
Agana, Guam 96910
Overseas Operator
(Commercial Call 646-8863)
Hawaii (EPA Form)
Chief, Noise and Radiation Branch
Hawaii Department of Health
591 Ala Moana Boulevard
Honolulu, Hawaii 96801
(808) 548-4129
Idaho (EPA Form)
Underground Storage Tank Coordinator
Water Quality Bureau
Idaho Department of Health & Welfare
Division of Environment
450 West State Street
Boise, Idaho 83720
(208) 334-4251
Illinois (EPA Form)
Underground Storage Tank Coordinator
Division of Fire Prevention
Office of State Fire Marshal
3150 Executive Park Drive
Springfield, Illinois 62703-4599
(217) 782-6760
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Indiana (EPA Form)
Division of Land Pollution Control, UST Program
Indiana State Board of Health
POB 7015
Indianapolis, Indiana 46207
(317) 243-5060
Iowa (State Form)
Iowa Department of Water, Air and Waste Management
900 East Grand
Des Moines, Iowa 50319
(515) 281-8692
Kansas (EPA Form)
Office of Environmental Geology
Kansas Department of Health and Environment
Forbes Field, Building 740
Topeka, Kansas 66620
(913) 862-9360 Ext. 221
Kentucky (State Form)
Natural Resources Cabinet
Division of Waste Management, Attn: Vicki Pettus
18 Reilly Road
Frankfort, Kentucky 40601
(502) 564-6716
Louisiana (State Form)
Patricia L. Norton, Secretary
Louisiana Department of Environmental Quality
POB 44066
Baton Rouge, Louisiana 70804
(504) 342-1265
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Maine (State Form)
Attn: Underground Tanks Program
Bureau of 011 & Hazardous Material Control
Department of Environmental Protection
State House -- Station 17
Augusta, Maine 04333
(207) 289-2651
Maryland (EPA Form)
Science and Health Advisory Group
Office of Environmental Programs
201 West Preston Street
Baltimore, Maryland 21201
(301) 383-7328
Massachusetts (EPA Form)
LIST Registry, Department of Public Safety
1010 Commonwealth Avenue
Boston, Massachusetts 02215
(617) 566-4500
Michigan (EPA Form)
Ground Water Quality Division
Department of Natural Resources
Box 30157
Lansing, Michigan 48909
(517) 373-1220
Minnesota (State Form)
Underground Storage Tank Program
Division of Solid and Hazardous Wastes
Minnesota Pollution Control Agency
1935 West County Road, B-2
Roseville, Minnesota 55113
(612) 296-7301
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Mississippi (EPA Form)
Department of Natural Resources
Bureau of Pollution Control
POB 10385
Jackson, Mississippi 39209
(601) 961-5171
Missouri (EPA Form)
Gordon Ackley, UST Coordinator
Missouri Department of Natural Resources
POB 176
Oefferson City, Missouri 65102
(314) 751-3241
Montana (EPA Form)
Solid and Hazardous Waste Bureau
Department of Health and Environmental Science
Cogswell Building, Room 8201
Helena, Montana 59620
(406) 444-3948
Nebraska (EPA Form)
Nebraska State Fire Marshal
POB 94677
Lincoln, Nebraska 68509-4677
(402) 471-2186
Nevada (EPA Form)
Attn: Underground Storage Tanks
Division of Environmental Protection
Department of Conservation and Natural Resources
Capitol Complex
201 South Fall Street
Carson City, Nevada 89710
(800) 992-0900, Ext. 4670
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New Hampshire (EPA Form)
Water Supply and Pollution Control Commission
Hazen Drive
POB 95
Concord, New Hampshire 03301
Attn: UST Registration
(603) 271-3503
New Jersey (State Form)
Underground Storage Tank Coordinator
Department of Environmental Protection
Division of Water Resources (CN-029)
Trenton, New Jersey 08625
(609) 292-0424
New Mexico (EPA Form)
New Mexico Environmental Improvement Division
Ground Water/Hazardous Waste Bureau
POB 968
Santa Fe, New Mexico 87504
(505) 827-2933, 2918
New York (EPA Form)
Bulk Storage Section
Division of Water
Department of Environmental Conservation
50 Wolf Road, Room 326
Albany, New York 12233-0001
(518) 457-4351
North Carolina (EPA Form)
Division of Environmental Management/Ground Water Section
Department of Natural Resources & Community Development
POB 27687
Raleigh, North Carolina 27611
(919) 733-5083
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North Dakota (State Form)
Division of Hazardous Waste Management & Special Studies
North Dakota Department of Health
Box 5520
Bismarck, North Dakota 58502-5520
(701) 224-2371
Northern Mariana Islands (EPA Form)
Chief
Division of Environmental Quality
POB 1304
Commonwealth of Northern Mariana Islands
Salpan, CM 96950
Overseas Operator: 6984
Cable address: GOV. NMI Salpan
Ohio (State Form)
State Fire Marshal's Office, UTN
Department of Commerce
8895 East Main Street
Reynoldsburg, Ohio 43068
State Hotline: (800) 282-1927
Oklahoma (EPA Form)
Underground Storage Tank Program
Oklahoma Corporation Commission
Jim Thorpe Building
Oklahoma City, Oklahoma 73105
(405) 521-2351
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Oregon
Underground Storage Tank Program
Hazardous and Solid Waste Division
Department of Environmental Quality
FOB 1760
Portland, Oregon 97207
(503) 229-5788
Pennsylvania (EPA Form)
Pennsylvania Department of Environmental Resources
Bureau of Water Quality Management/Ground Water Unit
9th Floor, Fulton Building
POB 2063
Harrisburg, Pennsylvania 17120
(717) 787-2814
Puerto Rico (EPA Form)
Director, Water Quality Control Area
Environmental Quality Board
Commonwealth of Puerto Rico
POB 11488
Santurce, Puerto Rico 00910-1488
(809) 725-0717
Rhode Island (EPA Form)
UST Registration
Department of Environmental Management
204 Cannon Building
75 Davis Street
Providence, Rhode Island 02908
(401) 277-2234
May be using a State form. Owners should consult EPA to determine
whether such form Is in compliance with Section 9002.
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OSWER DIR.9650.1
South Carolina (State Form)
Attn: Susana Workman
Groundwater Protection Division
South Carolina Department of Health & Environmental Control
2600 Bull Street
Columbia, South Carolina 29201
(803) 758-5213
South Dakota (EPA Form)
Office of Water Quality
Department of Water & Natural Resources
Joe Foss Building
Pierre, South Dakota 57501
(605) 773-4064
Tennessee (EPA Form)
Terry K. Cothron, Director
Division of Ground Water Protection
Tennessee Department of Health and Environment
150 Ninth Avenue, North
Nashville, Tennessee 37219-5404
(615) 741-7206
Texas (EPA Form)
Underground Storage Tank Program
Texas Water Commission
POB 13087
Austin, Texas 78711
(512) 458-7485
Utah (EPA Form)
Kenneth L. Alkema
Division of Environmental Health
POB 45500
Salt Lake City, Utah 84145-0500
(801) 533-6121
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Vermont (State Form)
Underground Storage Tank Program
Vermont AEC/Waste Management Division
State Office Building
Montpelier, Vermont 05602
(802) 828-3395
Virginia (EPA Form)
Russell P. Ellison, III, P.G.
Virginia Water Control Board
POB 11143
Richmond, Virginia 23230-1143
(804) 257-6685
Virgin Islands (EPA Form)
205(J) Coordinator
Division of Natural Resources Management
14F Building 111, Watergut Homes
Christianstead, St. Croix, Virgin Islands 00820
Washington (State Form)
Earl W. Tower, Supervisor
Department of Ecology, M/S PV-11
Management Division, Solid and Hazardous Waste
Olympia, Washington 98504-8711
(206) 459-6316
West Virginia (EPA Form)
Solid and Hazardous Waste/Ground Water Branch
West Virginia Department of Natural Resources
1201 Greenbriar Street
Charleston, West Virginia 25311
Attn: UST Notification
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Wisconsin (State Form)
Bureau of Petroleum Inspection
POB 7969
Madison, Wisconsin 53707
(608) 266-7605
Wyoming (EPA Form)
Water Quality Division
Department of Environmental Quality
Herschler Building, 4th Floor West
122 West 25th Street
Cheyenne, Wyoming 82002
(307) 777-7781
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APPENDIX D
D-l
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OSWER DIR.9650.1
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OSWER D1R.9650.1
APPENDIX D
Recommended Publications
CORROSION REFERENCES
American Colloid Company, (n.d.). Brochure No. 290A: Soil Sealants that
Confine Oil and Chemical Leaks or Spills. Environmental Products
Division, 5100 Suffleld Court, Skokie, II 60077.
American Colloid Company, (n.d.). Brochure No. 229L: Volclay Seepage
Control Systems. Environmental Products Division, 5100 Suffield Court,
Skokle, IL 60077.
American Concrete Institute Committee 515. 1963. "Guide for Protection
of Concrete Against Chemical Attack by Means of Coatings and Other
Corrosion-Resistant Materials," In ACI Journal Proceedings 63: 1305-92.
American Petroleum Institute 1983. API Publication 1632: Cathodic
Protection of Underground Petroleum Storage Tanks and Piping Systems.
1220 L Street, N.W., Washington, D.C. 20005.
American Petroleum Institute. 1977. API Publication 1621: Recommended
Practice for Bulk Liquid Stock Control at Retail Outlets. 1220 L Street,
N.W., Washington, D.C. 20005.
American Petroleum Institute 1984. API Publication 1635: Recommended
Practice for Underground Petroleum Product Storage Systems at Marketing
and Distribution Facilities. 1220 L Street, N.W., Washington, D.C.
20005.
Anonymous. 1979. "Composite Tanks Fuse Fiberglass to Steel via Polyestet
Resin Bond," in Petroleum Marketer: May-June.
Anonymous. 1973. "Steel Tank Institute's "Sti-P3" Tanks Combine
Three-Way Protection," in Petroleum Marketer: May-June.
Clemmer Industries, Ltd. 1981. Double-Walled Storage Tanks. 446 Alberi
Street, P.O. Box 130, Waterloo, Ontario, Canada N2J4A1.
Fitzgerald, J. H. 1975. Corrosion Control for Buried Service Station
Tanks. Paper presented at the International Corrosion Forum Devoted
Exclusively to the Protection and Performance of Materials, Toronto,
Canada. National Association of Corrosion Engineers, 1440 South Creek,
Houston, TX 77084.
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OSWER DIR.9650.1
Fitzgerald, J. H. 1981. Suggested Ways to Meet Protection Corrosion
Codes for Underground Tanks and Piping. The Hinchman Company, 1605 Mutual
Building, Detroit, MI 48226.
Gallagher, R. 1980. "Beat Corrosion With A Rubber Hose," in Chemical
Engineering. New York: McGraw-Hill.
Hamner, N. E. 1974. Corrosion Data Survey, Fifth ed. National
Association of Corrosion Engineers, 1440 South Creek, Houston, TX 77084.
Hasse Tank GmbH & Co. (n.d.). KG, The Double Wall Self-Monitored Tank.
Betco Associates, P.O. Box 350, Closter, NY 07624.
Haxo, H. E., Haxo, R. S., White, R. 1977. Liner Materials Exposed to
Hazardous and Toxic Sludges. EPA-600/2-77-081. Cincinnati, OH: U.S.
Environmental Protection Agency.
The Hinchman Company. 1981. Job Number 1079-4542: Suggested Ways to
Meet Corrosion Protection Codes for Underground Tanks and Piping. The
Hinchman Company, Corrosion Engineers, 1605 Mutual Building, Detroit, MI
48226.
Hosford, H. W. (n.d.). Paper No. HC-16: Cathodic Protection of Marine
Structures. Harco Corporation, Cathodic Protection Division, 1055 West
Smith Road, Medina, OH 44256.
Husock, B. (n.d.). Paper No. HC-4: Cathodic Protection - One Way to
Prevent Underground Corrosion. Harco Corporation, Cathodic Protection
Division, 1055 West Smith Road, Medina, OH 44256.
Husock, B. 1976. Paper No. NC-36: Causes of Underground Corrosion.
Harco Corporation, Cathodic Protection Division, 1055 West Smith Road,
Medina, OH 44256.
Husock, B. 1965. Paper No. HC-15: Corrosion and Cathodic Protection of
Underground Tanks at Service Stations. Harco Corporation, Cathodic
Protection Division, 1055 West Smith Road, Medina, OH 44256.
Husock, B. (n.d.). Paper No. HC-3: Corrosion Cathodic Protection and
Common Sense. Harco Corporation, Cathodic Protection Division, 1055 West
Smith Road, Medina, OH 44256.
Husock, B. 1962. Paper No. HC-2: Fundamentals of Cathodic Protection.
Harco Corporation, Cathodic Protection Division, 1055 West Smith Road,
Medina, OH 44256.
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OSWER DIR.9650.1
Husock, B. (n.d.). Paper No. HC-7: Use of Pipe-to-Soil Potential in
Analyzing Underground Corrosion Problems. Harco Corporation, Cathodic
Protection Division, 1055 West Smith Road, Medina, OH 44256.
National Association of Corrosion Engineers. 1985. NACE Standard
RP-02-85: Control of External Corrosion on Metallic Buried, Partially
Buried, or Submerged Liquid Storage Systems. 1440 South Creek, Houston,
TX 77084.
National Assocation of Corrosion Engineers. 1983. NACE Standard
RP-01-69: Control of External Corrosion on Underground or Submerged
Metallic Piping Systems. 1440 South Creek, Houston, TX 77084.
Petroleum Association for Conservation of the Canadian Environment.
1979. PACE Report No. 792: State of the Art Review - Petroleum Product
Containment Diking. Prepared for PACE by Colder Associates and James F.
MacLaren Limited, Suite 400, 130 Albert Street, Ottawa, Canada K1P564
R1zzo, F. E. (n.d.). Paper No. HC-14: Detection of Active Corrosion.
Harco Corporation, Cathodic Protection Division, 1055 West Smith Road,
Medina, OH 44256.
Rothman, P. S. 1978. Cathodic Protection of Tank and Underground
Structures. Harco Corporation, Cathodic Protection Division, 244 East
County Line Road, Hatboro, PA 19040.
Steel Tank Institute. Recommended Practice for Internal Corrosion
Protection. 666 Dundee Road, Northbrook, IL 60062.
Steel Tank Institute. 1983. Specification for sti-P3 System of External
Corrosion Protection of Underground Steel Storage Tanks. 666 Dundee Road.
Northbrook, IL 60062.
Steel Tank Institute. Standard for Dual Wall Underground Steel Storage
Tanks. 666 Dundee Road, Northbrook, IL 60062.
Tator, K. 8. 1972. "Protective Coatings," in Chemical Engineering
Deskbook Issue. New York: McGraw-Hill.
U.S. Department of Agriculture. 1971. Design Note No. 12: Control of
Underground Corrosion. Soil Conservation Service, Washington, D.C.
-------
OSWER DIR.9650.1
STRUCTURAL FAILURE AND INSTALLATION REFERENCES
American Petroleum Institute. 1979. API Standard 2510: The Design and
Construction of Liquified Petroleum Gas Installations at Marine and
Pipeline Terminals, Natural Gas Processing Plants, Refineries,
Petrochemical Plants, and Tank Farms. 1220 L Street, N.W., Washington,
D.C. 20005.
American Petroleum Institute. 1979. API Publication 1615: Installation
of Underground Petroleum Storage Systems. 1220 L Street, N.W.,
Washington, D.C. 20005.
Bixby, J. L. 1973. "Underground Steel Storage Tanks," in The
Construction Specifier. The Construction Specifications Institute,
Alexandria, VA.
Steel Tank Institute. 1983. A Specifier's Checklist Guide to Underground
Storage Systems. 666 Dundee Road, Northbrook, IL 60062.
Underwriters' Laboratories, Inc. 1983. UL 1316: Glass Fiber Reinforced
Underground Storage Tanks for Petroleum Products. 333 Pfingsten Road,
Northbrook, IL 60062.
Underwriters' Laboratories, Inc. 1976. UL 58: Steel Underground Tanks
for Flammable and Combustible Liquids. 333 Pfingsten Road, Northbrook, II.
60062.
COMPATIBILITY REFERENCES
American Petroleum Institute. 1983. API Publication 1631: Recommended
Practice for the Interior Lining of Existing Steel Underground Storage
Tanks. 1220 L Street, N.W. Street, N.W., Washington, D.C. 20005.
Falck, S. B. 1972. "Process Tank Linings," in Chemical Engineering
Deskbook Issue. New York: McGraw-Hill.
Gallagher, R. 1980. "Beat Corrosion With A Rubber Hose," in Chemical
Engineering. New York: McGraw-Hill.
Hamner, N. E. 1974. Corrosion Data Survey, Fifth ed. National
Association of Corrosion Engineers, 1440 South Creek, Houston, TX 77084.
McAnaly, M. A., Dickerman, J. C. 1976. API Publication No. 4278:
Summary and Analysis of Data From Gasoline Temperature Survey Conducted at
Service Stations by American Petroleum Institute. Radian Corporation,
8500 Shoal Creek, Austin, TX.
-------
OSWER DIR.9650.1
New York Testing Laboratories, Inc. 1983. Compatibility Report.
Perry, R. H., Chilton, C. H. 1973. Chemical Engineers' Handbook. Fifth
ed. New York: McGraw-Hill.
Rolston, J. Albert. 1985. "Dual-Polymer Laminates for
Corrosion-Resistant Equipment," in Chemical Engineering. New York:
McGraw-Hill.
Steel Ta'nk Institute. 1985. Establishing the Effect of Long-Term
Exposure of Fiberglass Reinforced Polyester Material to Alcohol-Gasoline
Mixtures, by L. J. Broutman and Associates, Ltd. 666 Dundee Road,
Northbrook, IL 60062.
Sax, Irving N. 1979. Dangerous Properties of Industrial Materials. New
York: Van Nostrand Reinhold Company.
Tator, K. B. 1972. "Protective Coatings," in Chemical Engineering
Deskbook Issue. New York: McGraw-Hill.
U.S. Department of Transportation. 1985. Chemical Hazards Response
Information System (CHRIS) Manuals. U.S. Coast Guard, Washington, D.C.
U.S. Environmental Protection Agency. 1980. A Method for Determining thi
Compatibility of Hazardous Hastes. EPA 600/2-80-076. Cincinnati, OH:
U.S. Environmental Protection Agency.
Windholy, M., et al. 1976. The Merck Index. An Encyclopedia of Chemicals
and Drugs. 9th ed. Rahway, NJ: Merck & Company, Inc.
OTHER TECHNICAL READINGS
ARCO Petroleum Products Co. (n.d.) HTC Service Station Tank Leak
Tester. Harvey Technical Center, 400 East Sibley Blvd., Harvey, IL
60426.
American Petroleum Institute. 1976. Chapter II - Conditions Causing
Deterioration or Failures. Chapter XI - Pipes, Valves and Fittings.
Chapter XIII - Inspection of Atmosphere and Low Pressure Storage Tanks.
In Guide for Inspection of Refinery Equipment. 1220 L Street, N.W. ,
Washington, D.C. 20005.
Anonymous. 1980. "Leak Detection: Still Top Priority," in Petroleum
Marketer: June.
-------
OSWER DIR.9650.1
Anonymous. 1980. "Sunmark Leak Lokator Meets NFPA Standards," In
Petroleum Marketer: September - October.
Baumeister, T., Avallone, E. A., Baumeister III, T. 1978. Marks'
Standard Handbook for Mechanical Engineers, Eighth ed. New York:
McGraw-Hill.
Ethyl Corp. (n.d.). "Ethyl" Tank Sentry (Underground Tank Leak
Detector). Petroleum Chemicals Division, 2 Houston Center, Suite 900,
Houston, TX 77002.
Heath Consultants, Inc. (n.d.). Form #582 HPN 5124: Procedure Manual
for the Operation of the Petro Tlte Tank Tester. Heath Consultants, Inc.
100 Tosca Drive, Stoughton, MA 02072.
Heath Consultants, Inc. (n.d.). Form #583 HPN 5254: Procedure Manual
for the Operation of the Petro Tlte Tank Tester. Heath Consultants, Inc.
100 Tosca Drive, Stoughton, MA 02072.
J&T Ecology Corp. (n.d.). JTEC-979: Industrial-Chemical Storage Tanks,
200 Lambert Avenue, Coplague, NY 11726.
Maresca, J. W., Evans, P. C. 1979. Measurement of Small Leaks in
Underground Gasoline Storage Tanks Using Laser Interferometry. SRI
International, Menlo Park, CA 94025.
McLean, F. R. 1971. A Test in Progress Using a Kent-Moore Tank Systems
Tightness Tester - Model 1000. Paper sponsored by the American Petroleum
Institute and presented at the 43rd Annual Fire Department Instructors
Conference March 30 - April 2, 1971, in Kansas City, MO.
McLean, F. R. 1971. Leak Seeking in Underground Tanks. Proceedings of
the Forty-third Annual Fire Department Instructors Conference, March 30 -
April 2, 1971, in Kansas City, MO.
National Fire Protection Association. 1975. NFPA 49: Hazardous
Chemicals Data. Batterymarch Park, Qulncy, MA 02269.
New York State Department of Environmental Conservation. 1980. New York
State Bulk Storage Control - Study Program. 50 Wolf Road, Albany, NY
12233.
Owens-Corning Fiberglas Corp. 1980. Pub. No. 3-PE-6312L: Fiberglass
Tanks for Fuel Storage, Non-Corrosive Products Division, Fiberglas Tower.
Toledo, OH 43659.
-------
OSWER DIR.9650.1
Perry, R. H., Chilton, C. H. 1973. Chemical Engineers' Handbook. Fifth
ed. New York: McGraw-Hill.
Petroleum Association for Conservation of the Canadian Environment
(PACE), (n.d.). Proceedings of the May 1982 Tank Testing Symposium held
1n Toronto, Canada. 1202-275 Slater Street, Ottawa, Canada KIP 5H9.
Petroleum Association for Conservation of the Canadian Environment (PACE)
(n.d.). Report No. 82-3: Underground Tank Systems: Review of State of
the Art and Guidelines. 1202-275 Slater Street, Ottawa, Canada KIP 5H9.
Scully Electronic Systems, (n.d.). Technical Data Sheet on Scully WG100C
Water Detector. Industrial Way, Wilmington, MA 01887.
Sunmark Industries, (n.d.). The Sunmark Leak Lokator Technical
Bulletin. P.O. Box 7368, Philadelphia, PA 19101.
U.S. Environmental Protection Agency. 1979. Hazardous Materials Spi11
Monitoring and Safety Handbook and Chemical Hazard Guide. Parts A and B.
EPA-600/4-79-008a/b, PB295853 and PB295854. Las Vegas, NV: Office of
Research and Development.
STANDARDS
American Petroleum Institute. 1979. API Standard 2510: The Design and
Construction of Liquified Petroleum Gas Installations at Marine and
Pipeline Terminals, Natural Gas Processing Plants, Refineries,
Petrochemical Plants, and Tank Farms. 1220 L Street, N.W., Washington,
D.C. 20005.
National Association of Corrosion Engineers. 1985. NACE Standard
RP-02-85: Control of External Corrosion on Metallic Buried, Partially
Burled, or Submerged Liquid Storage Systems. 1440 South Creek, Houston,
TX 77084.
National Assocatlon of Corrosion Engineers. 1983. NACE Standard
RP-01-69: Control of External Corrosion on Underground or Submerged
Metallic Piping Systems. 1440 South Creek, Houston, TX 77084.
National Fire Protection Association. 1984. NFPA 30: Flammable and
Combustible Liquids Code. Batterymarch Park, Quincy, MA 02269.
National Fire Protection Association. 1983. NFPA 58: Standard for the
Storage and Handling of Liquefied Petroleum Gas. Batterymarch Park,
Quincy, MA 02269.
-------
OSWER DIR.9650.1
National Fire Protection Association. 1984. NFPA 59: Standard for the
Storage and Handling of Liquefied Petroleum Gas at Utility Gas Plants.
Batterymarch Park, Quincy, MA 02269.
National Fire Protection Association. 1983. NFPA 329: Underground
Leakage of Flammable and Combustible Liquids. Batterymarch Park, Quincy,
MA 02269.
Steel Tank Institute. Standard for Dual Wall Underground Steel Storage
Tanks. 666 Dundee Road, Northbrook, IL 60062.
Underwriters' Laboratories, Inc. 1983. UL 1316: Glass Fiber Reinforced
Underground Storage Tanks for Petroleum Products. 333 Pfingsten Road,
Northbrook, IL 60062.
Underwriters' Laboratories, Inc. 1976. UL 58: Steel Underground Tanks
for Flammable and Combustible Liquids. 333 Pfingsten Road, Northbrook, IL
60062.
For further information on specifications for tank materials and
construction, contact the organizations listed below:
CARBON STEEL
American Iron and Steel Institute
1000 Sixteenth Street, N.W.
Washington, D.C. 20036
American National Standards Institute
1430 Broadway
New York, NY 10018
Information on standards and specifications of the Canadian Standards
Association and the International Organization for Standardization may
also be obtained from ANSI.
American Petroleum Institute
1220 L Street, N.W.
Washington, D.C. 20005
American Society of Mechanical Engineers
345 East 47th Street
New York, NY 10017
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OSWER DIR.9650.1
American Society for Testing and Materials
1916 Race Street
Philadelphia, PA 19103
American Welding Society
2501 N.H. Seventh Street
Miami, FL 33125
National Association of Corrosion Engineers
1440 South Creek
Houston, TX 77084
National Fire Protection Association
Batterymarch Park
Quincy, MA 02269
Steel Tank Institute
666 Dundee Road
Northbrook, IL 60062
Underwriters' Laboratories, Inc.
333 Pfingsten Road
Northbrook, IL 60062
FIBERGLASS-REINFORCED PLASTIC
American Society for Testing and Materials
1916 Race Street
Philadelphia, PA 19103
National Fire Protection Association
Batterymarch Park
Quincy, MA 02269
Underwriters' Laboratories, Inc.
333 Pfingsten Road
Northbrook, IL 60062
TANK RELINING - SURFACE PREPARATION
Steel Structures Painting Council
4400 5th Avenue
Pittsburgh, PA 15213
-------
OSWER DIR.9650.1
APPENDIX E
E-l
-------
OSWER DIR.9650.1
HAZARDOUS SUBSTANCE LIST
FOR REGULATION OF UNDERGROUND STORAGE TANKS
UNDER RESOURCE CONSERVATION AND RECOVERY ACT,
SUBTITLE I
Hazardous Substance
Acenaphthene
Acenaphthylene •
Acetaldehyde . • .
Acetaldenyde. chloro- ,
Acetaldenyde. tnctiioro- - -
Acetamide N-(amino!hioxomethyi)-
Acelamide. N-(4-ethoxyphenyl)- .
Acetamide. N-9H-fluoren-2-yl-
Acetamide. 2 tluoro-
Acettc acid
Acetic acid, etnyl ester . •
Acetic acid, fluoro-, sodium salt
Acetic acid, leas sal! ...
Acetic acid, thalium(l| salt
Acetic anhydride
Aceiimidic acid N.((memylcarbomoyl) oxy| thio.
metPv1 ester
Acetone
Acetone cyanonydnn
Acetonitnie
3-ialofia-Acetoryioenzyl}- 4-hydroxycoumann and
salts
Acetopnenone
2 Ace'vlaminci'uore . .
Benzenamme. 2-methyl-, hyarochionde . ..
Benzenamtne, 2-methyl-5-nitrr> . . .
Benzenamme 4-nitro-
Benzene
Benzene. 1 -Oromo-4-phenoxy-
Benzene chloro-
Benzene chloromethyi-
Benzene 1 2-dichloro-
Benzene 1-3-dichtoro-
Benzene.1 ,4-dichloro-
Benzene dichtoromethyt-
Benzene 2 4-dnsocyanatometrryi
Benzene dimethyl
m-
0-
P-
Benzene. hexachloro-
Benzene. hexahydro-
Benzene, hydroxy-
Benzene. methyl-
Benzene, 1 -metnyl-2.4-dmilro-
Benzene. 1 -methyl-2.6-dinitro-
Benzene. t.2-memylenedioxy-4-allyl-
Benzene. 1 2-methylenedioxy-4-propenyi-
Benzene. 1 2xylic acid annydnde
1 2-Benzenedicarboxylic acid [bisl2.etr>yiexyH]
ester
1 .2 Bonzsnedicarooxytic acid, dibutyl Mter
1 ,2-Benzenedicattxnyiic acid, dwoiyi ester
CASRN
542621
56495
225514
225514
98873
5655.?
565SS
57976
62533
492808
106478
3165935
601 >/
101 K^
6362V.
99551
100016
7143?
101553
1089C/
100447
95501
54173!
10646/
98373
584S49
91087
26471625
133020?
10838;*
95470
10642T
1 18741
U08J7
1089»
10888;!
121142
606202
94597
120561
94586
98828
98953
608935
82688
95943
98077
99354
510156
85446
117861,
1
847V
84662
•Chemical Abstracts Service Reoistrv Number
-------
OSWER DIR.9650.1
Hazardous Substance
' 1 ,2-Benzenedicartx)xylic actd. dimethyl aster
1 2-Benzenedicarboxyiic acid, di-n-oclyl aster
1 ,3-Benzenediol
1 2 8enzenediol 4-(1 hydroxy-2-(meihyiaminoieihyi]
Senzenasulfonic acid chlonde
Benzenesulfonyl cnionde
Benzenethiol .
Benzrdme
l ' 2-8enzisoihiazoiin-3-one,1,!.diojenyl).4,4 diam.ne.3.3' dicdkxo-
(t,r-8iphenyl)-4.4' dianww.3,31 dimelrwry-
(1 t Biphenyl)-4,4-diamine.3.3'-dim«nyl-
Bis (2-ehloroethyl) emer _
Bis(2-chloro
-------
OSWER DIR.9650.1
Hazardous Substanc*
CASRN
Hazardous Substance
CASRN
Hazardous Substance
CASRN
Cupnc acetate
Cupnc aoatoarsanrM
Cupnc chloride
Cupnc rant*
Cupnc oxalate . .. .
Cupnc sultan
Cupnc sulfata ammooiated . . .
Cupnc tartrate
CYANIDES
Cyanidas (soluble cyanide salts), not elsewhere
specified
Cyanogen
Cyanogen bromide
Cyanogen chloride
1,4-Cyclonexadienedione
Cyclohexane
Cyciohexanone
1.3-Cyclopemadiene. 1,2.3,4 5 5-hexachloro-
Cydophosphamide .
2 4-D Acid
2,4-0 Esters
2.4-0. salts and esters . . ..
Daunomycin
ODD
4.4' DOO
DOE
4.4' DDE
DOT
4.4'DDT
DOT AND METABOLITES
Oecachloroctanydro-1 3.4-metneno-2H-
cyclGbuta(c d|-pemalen-2-one
Oiallate
Diamine .
DiamtnotDKjene
Diazinoo
Oibenzla n|antnracene
1.2 5,6-Oibenzanthracene . ..
Dibenzo(a h|anthracene
1 2 7,8-Oibenzopyrene
'Dibenz(a ijpyrene
1,2-Oitxomo-3-chloropropane
Dtbutyl phthalate
On-outyl pnthalaw . .
.dcamba
Oichtabenil .
Otchlon* ....
S-<2.3-Dichloroallyl) drtsopropyiihiocarbamate
35-6ichKxc-N-chlorot>enzene (mixed) 25321228
,2-Oicnlorobenzene 95501
3-Dichlorobenzene 54173t
,4-Oichlorobenzene . . 106467
m-Oichlorobenzene . . 541731
•Oichlorobenzene 95501
Oichlorcbenzsne . 106467
DICHLOROBENZIDINE
3 3 -Oichlorobenzidine . 91941
Oichlorobromomethane . . 75274
1 Oirnk-n L Sjtone . 764410
Dicnlorodtfluorometnane 75718
Dichtorodipnenyt dichloroethane . 72548
Dichlorodipheny! tncnloroethane 50293
1 •Dichioroetnane 75343
2-Dichkxoethane . .. 107062
. 1 -Oichloroelnylene 75354
.2 Irans-Dtcnloroethylene 156605
Dichloroethyi etner 111444
2 4-Dichtorophanol 120832
i 6-Dichlorophcnol 87650
2 4 D'ChlcropnenoxyaCRtic acid salts and eslers 94757
Oichtoropnenylarsine 6962B6
.cntoroptopane 26638197
1 t-Dichloropropane i 78999
' 3-DichlorODropane 142289
2-Oichloropropane . 78875
D'Cfiloropropane • Dichloropropene (mixture) 8003198
Dichloropropene . 26952238
2.3-Dichloropropene 78886
3-Dichloropropene . J 542756
2.2-Dicnloropropipnic acid - 7"i990
Dichlorvos . 62737
Dieldnn . 60571
1.2 3.4-Oiepoxybutane .... . . 1464535
Oietnylamme . . . 109897
Diethylarsine . 692422
1.4-Diethylene dioxide , 123911
N.N'-Diethylhydrazme . 1615801
O.O-Diethyl S-!2-(etnyi;niolethyl]pnospnoroditnioate 298044
OO-Die(hyl S-me'hyl dithiophobphale 3288582
Diettiyt-p-nitropnenyl phosphate . . 311465
Diethyl phthalale 84662
O,O-Otethyt 0-pyrazmyl phosphorothioate . 297972
Dielhylstilbesif.l 56531
1,2-Oihydro-3,6-pyndazinedione , 123331
Dihydrosalrole . 94588
Dnsopfonyt tluoropnosphate 55914
Oimethoate . 60515
3.3'-DimelhoKybenzidine 119904
Dcmethylamine . 124403
Dimethylarmnoazobenzene 60117
7,12-0imelhylbenz!a)anthracene . 57976
3.3'-Oimethylbenzidine 119937
alpha. alpha-Oimethyibenzyihydroperoxide 80159
1-3 Dimethyl-l methylthio)-2-bulanoneO- 39196184
[(melhylafnino)carbonylj oxime
DimethylcarDamoyl chloride . 7944'
i-Oimtthytnydnuine ......
2-OimMliylhydnuin* .....
O.O-Oim«lhyl O-p-nmophanyl pnosphoromioaM
Ounetnylnitrouniin*
alpna. atpha-OimethylphenMhylamme
2.4-Oimetnylphenol
Oimathyf pnttwlau
Dimethyl sultata .
Oimtfobenzene (mixed)
4.6-Dntro-o-cresol and salts
4.6-Oinnro-o-cyeloh«ryipn«X)l
Dmitrophenol - • -
2.5-
2.6-
2.4-Omitroph«nol .....
Omrtrotoluene
3.4-Omitrotoluene
2.4-Dinitrotoluena
Omoseb
Di-n-octyl phthalate
1 4-Oioxane
OIPHENYLHYORAZINE
1 ,2-Diphenyinydrazme
Diphosphoramide. octamethyl-
Dipropylamine
Di-n-propylnitrcsamine
Diqual
Disulfoton
2.4-Oithiobiuret
Dithiopyrophosphonc acid, telraethyl ester
Diuron
Oodecylbenzenesuifonic aod
EndosuKan
alpha- Endosulfan
beta-Endosuttan
ENOOSULFAN AND METABOLITES
Ensodultan sultate
Endothall
Endnn ....
Endnn aldehyde
ENDRIN AND METABOLITES
Epichkxohydnn
Epinephnne
Ethanal
Emanamme 1 1-dimethyi-2 phenyl-
Ethanamme N-e(hyt-N-nitroso-
Elhane. 1 ,2-dibromc-
Ethane. 1.1-dichloro-
Ethane. 1 ,2-dichloro-
Ethane, 1,1.1 2.2.2-hexachioro-
Ethane. 1 1 •[methyteneOis(oxy)|bis(2-chloro-
Ethane, 1,1 -oxybis-
Etfiane.t.1 -oxyOis(2-chloro-
Ethane, pantacMoro-
5714?
540738
298000
62759
122098
105679
131113
777P.I
251545".'.
9965
-------
OSWER DIR.9650.1
Hazardous Substance
Ethane 1 1 . 1 ,2-tetrachloro-
Elhane 1 1 2.2-tetrachioro-
Ethane, 1 ! .2-tnchloro-
Elhane. 1.1,1 -tnchloro-2.2-bis(p-m«lhoxypnenyl).
1 2 Eihanediyfb'scarbamodunioic acid
Ethanenunle
Ethanethioamide
Ethanol 2,2'-(hitrosocmino|bis-
Ethanone. 1-phenyl-
Ethanoyl chlonde
E'honamme N-methyl-N-nilroso
Ethene chloro-
Elhene 2 chloroethoxy
Etfiene, 1,t-dicf*oro-
Ethene. 1,1.2.2-tetrachiorc-
Ethene. trans- 1 .2-dichlorc-
Ethion
Ethyl acetate
Ethyl acryiate
Ethylbenzens
Ethyl carbamate (Urethan)
Ethyl cvanide
Ethyl 4 4 -dichloroDenzilate
Ethyiene dibromide
Ethyiene dicri'onde
Ethyiene oxide
ElhylenebisldithiocarBamic acid)
Ethylenediamme
Ethyienediamme tetraacetic acid (EOTA)
Elhylenethiourea
Ethyienimine
Etfiyl ethar
Ethylidene dichlonde
Ethyt methacrylate
Famphur
Feme ammonium citrate
Feme ammonium oxalata .
Feme chlonde ...
Feme nitrate
Fernc sulfate
Ferrous ammonium sulfate . .
Ferrous chloride
Ferrous sulfate ...
Fluoroacettc acid, sodium salt
Fluoranfhene .. .
Fluorene
Fluorine
Fluoroacetamide
Formaldehyde
Formic acid
Fulmiruc acid. mercury(ll)salt
CASRN
S30206
79345
790X35
72435
111548
75058
62 555
1116547
98862
75365
1549400
75014
110758
75354
12718*
156605
563122
141786
140885
100414
51796
107120
510156
106934
107062
75218
111546
107153
60004
96457
151584
60297
75343
97832
62500
528S7
1185575
2944674
55488874
7705080
9004664
7783508
10421484
10028225
10045893
7758943
7720787
7782630
62748
206440
86737
7782414
640197
50000
64188
628864
Hazardous Substance
Fumanc acid
Furan
Furan, tetrahydrc-
2-Furancaroox«idenyde
2.5-Furandnne
Furfural
=urfuran
D-Giucooyranose 2 deoxy-2
O-molhyl-J-mlrosoureido)-
Qtyodylaldafiyaa
Guanidme. N-mtroso-N-methyl-N'-nilro
Gutfuon
HALOETHERS .
HALOMETHANES
Heptachlor
Hexachlorooenzene
Hexachlorocyclohexane (gamma isomer)
Hexachlorocyclopentadiene
1 234 10 10 Hexacrloro 67eooxy
1 4 4,1 56 733.1 oc:aMvdro endoendo
' •' 5 8-dimelhanon^orilhalene
1 23.4 10. 10-Hexacf^oro-6.7-epoxy-
1 .4 4a,5.6.7 8 8a- octahydro-endo exo-
1.4 5.8-dimethanonaphthalene
Hexachloroethane
Hexachlorohee . .
Indenoil 23-cd)pyrene
Iron dextran . .
Isooutyt alcohol ... ...
CASRN
110178
110009
109999
98011
108316
98011
110009
18883664
765344
70257
86500
76448
118741
608731
58899
77474
'2208
60571
67721
465736
465736
309002
70304
1888717
757584
302012
1615801
57147
1226f
60344
79196
7647010
74908
7664393
74908
7664393
7803512
7783064
80159
7783084
75605
96457
193395
9004664
78831
Hazardous Substance
socyanic acid, methyt ester
sophorone
soprena
sc«ropanolaminedooecylBanzarie*ulfonala . ..
aosafroia
3(2H)-lsoooo- .
Methane oxyDistchloro-
t
CASRs- ;
1
624839
7858 i
76 W>
42504461
120S81
27639S4
115S??
1435ff-i
303JK-;
743SS?1
301Wi-
7784409
7845252
101024&-1
775885-!
1381496';
7783^6'
1010H^'
1009S74€
744S2'/
7428480
10723S1
5618909^.
52652592
133532C
1 573980?
7446W
131*fiV(i
5928 'U
58899
14307358
121755
110167
108316
123331
1486?3
592041
10045S<'0
77833!>S
5928S8
104157S5
7782867
7439978
62384
628864
126987
124403
74839
74873
107302
74953
75092
7S718
7488*
S428S-!
-------
OSWER DIR.9650.1
Hazardous Substance
Methane. tetr«chloro- ....
Mattune letranit
Methane, tnbromo-
Methane, tnchtoroduora- ... . .
Methaneeultonic aod. etfiyl eater
MethanetNoi . .
MMttanmullenyl chlonde. tnchloro- ..
4.7-Melhano-1H indene. 1.4.56.788 hppliichlcro-
3a 3.7 7a-tetranyoro
Metnanotc acid . . .
4.7-Metnanoindan. 1 . 2.4. 5.6.7. 8.8-octachtoro-
3a,4,7,7a'tetrahydro-
Methane*
Metnapyniene
Methomyl
Methoxychlor
Methyl alcohol
2-Methylazmdme
Methyl bromide
1-Methylbuiadiene
Methyl chloride
Methyl chforocarbonate
Methyl chloroform
4 4.Mf>!hyleneoisi2 -hlofoanilme)
2,2 -Methylenebis(3 4 6-tnchlorophenol)
3-Methylcholanthrene
Methylene Qrcmide
Metnylene chloride
Methyleiie oxide
Methyl ethyl ketone
Methyl ethyl kelone peroxide
Methyl hydrazine
Methyl ioaide
Methyl isobutyl ketone
Methyl isocyanata . ...
2-Mettiytlacionrtnle
Methylmercaptan
! Mettiyl methacrylate . .
N-Methyi-N'-nitro-N-nitrosoguanidtne . ...
. Methyl parathion
1 4-Methyl-2-6entanone
Methylthiouracil
, Mevinpnos
1 Mexacamate
Milomycin C
Monoethylamme
', Monomethylamme
Naled
5 12-Naphthacenedione, (8S-cis)-8-acetyl-10-
i [3-ammo-2 36-lrideoxy-alpha-l lyxo-
hexopyranosyl)o»vl-78.9 10-tetrahydro-
68 11-trihydroxy-l-methoxy-
1 Naphthalene. 2-chloro-
. Naphthalene. 2-chtoro-
l| 1 ,4-Naphthalenedione
I
CASRN
5o235
509148
75Z52
67663
75694
62500
74931
594423
76448
64186
57749
67561
91805
16752775
72435
67561
75558
74839
5046O9
74873
79221
'"1556
101144
70304
56495
74953
75092
50000
78933
1338234
60344
74884
108101
624839
75865
74931
80626
70257
2980CO
108101
56042
7786347
315184
50077
75047
74895
300765
20830813
91203
91587
130154
Hazardous Substance
2 7 Naphlhalenedisulfomc acid 3.3:|(13;dimelhy|.
|l,f- oiphenyi)-4 4:diyl)-bis(azo)|bis(5-amino-
4-hydroxyHetrasodium sail
Naphthenre acid
1 4-Napthoqumone
1 -Naphthylamine
2-Naphthylamme
alpha-Naphthylaminx
beta-Naphthylamine
2-Naphihyiamtne N.N-bis(2-criloroethyi)-
alptn N.iphinylthalhiourea
Nickel ft
NICKEL AND COMPOUNDS
Nicxel ammonium sulMte
Nickel carbon/I
Nickel chloride
Nickel cyanide
Nu-iHii'i panicle
Nickel hydroxide
Nickel nitrate
Nickel sultate
N>ckei tetracarbonyl
Nicotine and salts
Nitric acid
Nitric oxide
p-Nitroanilme
Nitrobenzene
Nif-ogen dioxide
Nitrogen(ll) oxide
NilroqenllV) oxide
Nitroglycerine
Nitrophenol (mixed)
m-
0-
P-
p-Nitrophenol
2-Nitrophenol . ...
4-Nttrophenol .
NITROPHENOLS
2-Nnropropane
NITROSAMINES
N-Nitrosodi-n-butyiamine
N-Nrtrosodiethanoiamine
N-Nitrosodiethylamme
N-Nitrosodimethylamme
N-Nitrosodiphenylamine
N-Nitosodi-n.propylamme
N-Nitroso-N-ethylurea
N-Nitroso-N-methylurea
N-Nitroso-N-methylurethane
N-Nitrosomethyivinylamine
N-Nitrosopiperidme
N -Nitrosopyrroiidine
Nitrotoluene
m-
0-
P-
,5-Niiro-o-ioluidine
CASRN
72571
1338245
1301S4
134327
91588
1343S7
91598
494031
86884
7440020
15699180
13463393
7718549
37211055
557197
557197
12054487
14216752
7786814
13463393
54115
7697372
10102439
100016
98953
10102440
10544726
10102439
10102440
10544726
55630
25154556
554847
88755
100027
100027
88755
100027
79469
924163
1 1 16547
55185
62759
86306
621647
759739
684935
615532
4549400
100754
930552
1321126
99081
88722
99990
99558
Hazardous Substance
S-Norbornene-2.3-dimemanol.1 4 5.6.7 7-
hexachloro. cyclic sultite
OctamethylpyTOphosphor amide
Osmium oxide
Osmium tetroxide
7-Oxaoicyclo[2 2 i)neptane-2.3-dicarboxylic acid
1 2-Oxathiolnne 2 2 dioxide
2H-1,3.2-Oxazapnosononne.2-ibis(2-cnioroethyi)
aminol tetrahyoro-2-oxide
Oxirane
Oxirane. 2-(chloromethyO-
Paralormaldenyde
Paraldehyde . .
Parathion ...
Pentachtorobenjene
Pentachioroethane
Pentachloronitroberuene
Pentachlorophenol
1 3-Pentadiene
Phenacetin
Phenanthrene
Phenol
Phenol 2-chioro-
Phenol 4-chloro-3-fTiethyl-
Phenol ^ c>clohtfx/|.4 6 0,r- :rc
Phenol 2 4-otchtoro-
Phenol. 2 6-dichloro-
Phenol 2 4-dimethyl-
Phenol 2 4-dinitro-
Phenol 2 '. dtm';o 6-11 ^ethvlc-roovii
Phenol. 2 4-dinitro-6-methvt and salts
Phenol 4-nttro-
Phenol, pentacnloro-
Phenol 2 346-tetrachloro-
Phenol. 2.4 5-tnchloro-
Phenol 2 4,6-lriChloro-
Phenol, 2.4,6-tnmtro-. ammonium salt
Ph«nyt dichloroarsine
1 . 1 0-1 1 ,2-Phenyieneipyrene
Phenylmercunc acetate
N-Phenylthiour«a
Phorate
Phosgene
Phosphine
Phosphonc acid
Phosphoric acid.diethyt p-mtrophenyl ester
Phosphonc acid, )ead salt
Phospnorodilhioic acid OO dietnyl S-melhylester
Phosphorodithraic acid O.O-d'ethyl S-(ethyithio),
methyl ester
Phosphorodithioic acid. O.O-dimethyl S-
[2(methylammo)-2-oxoethyil ester
Phosphorotluondic acia Pisd ^nelhyiethyltestpr
Phosphorothioic aod.O.O-diethyl 0-lp-nitrophenyl)
ester
Phosphorothioic acid. O,O-diethyt O-pyrazinyl ester
Phosphorothioic acid O O-oimethyl O-|p-
[(dimethytamino)-surlonyl|pnenyl] ester
CASHN
11529?
15216H
20816120
20016120
145733
50180
75.?"!
'.06893
30525694
123637
56382
608935
76017
82688
87865
504609
62442
85018
•08952
95578
59507
i 3 1 895
1 20832
87650
105679
b'285
88857
534521
100027
87865
58902
9595.1
88062
'31740
696286
10339S
62384
10385;
2981VJ
75445
7803512
7664382
311455
7446277
3288582
298022
60515
55914
56382
29797?
52857
j
-------
OSWER DIR.9650.1
Hazardous Substance
Phosphorus
Phosphorus oxyciilonde . -
Phosphorus pentasulfioe
Phosphorus sulfida
Phosphorus tnchlonde
PHTHALATE ESTERS ... -
Phthalic anhydnde
2-Pioolme
Piumoane. tetraethyl-
POLYCHLORINATED BIPHENYLS (PCBs|
POLYNUCLEAR AROMATIC HYDROCARBONS
PoiasS'um a'senate
Potassium arsenite
Potassium bichromate
Potassium chromate
Potassiium cyanide
Potass'um hydroxide
PotasSi^Ti permanganate
Potassium silver cyanide
Prcnamiae
i -Propanai ^ 3-epoxy-
Propa"al. 2-rrethyl-2-(methyithio)-.O-[(methyiamin<
caroonyl]oxime
i-P'Opanamine
1 -PTOpanamine. N-propyl-
Propane 1 2-dihromo-3-chloro-
P'opane 2-nitro- . . . .
Proaane 2 2-oxybis(2-chioro-
1.3-Propane sultone
Propanedmitnle.. .
Propanemtnle
Propanemtnle. 3-chloro- ,
Propanenrtnle. 2-hydroxy-2-methyt- .,
1,2.3-Prooanetnol, tnnitrate-
1 -Propanol. 2.3-dibromc-, phosphate (3:1)
1-"Propanol. 2-methyl-
2-Propanone ..
2-Propanone. 1-bromo
Propargite . .
Propargyl alcohol . ...
2-Propenal
2-Propenamide ... .
Propene 1,3-dichloro-
1-Propene. 1.1 2.3.3.3-hexachtoro- . . .
2-P'Openenitnle .
2-Prooenenitnl*. 2-methyl-
2-Propenoic acid ...
2-Prooenoic acid, ethyl ester
2-Propenoc acid. 2-methyi-, ethyl est«r
2-Propeoenc acid. 2-merhyt-, methyl ester ...
2-Prooen-i-oi
Propionic acid
CASRN
7723140
10025873
1314803
1314803
7719122
85449
109068
78002
1336363
12674112
11104282
11141165
53469219
12672296
11097691
11096325
7784410
10124502
7778509
7789006
151508
1310583
7722647
506616
23950585
765344
116063
107108
142847
96128
79469
108601
1120714
109773
107120
S427S7
75865
55630
126727
78831
67641
598312
2312358
107197
107028
79061
542756
1888717
107131
126987
79107
140885
97632
80626
107186
79094
Hazardous Substance
Propionic actd. 2-12.4.5-lnchloropr'enoxy}-
Propionic anhydnde
n-Propylamme
Propylene dichlond*
Propylene oxide
1 2-Propytenimine
2-Propyn-1-ol
Pyrene
Pyrelhnns
4-Pyridinamine
Pyndme
Pyridme 2 [(2-(dimethlyaminotelhyl!-^-thenylamino|
Pyndme. hexanydro-N-mtroso-
Pyndine.2-melhyl-
Pyndme. {S)-3-(1-methyl-2-pyrroiidmy))- and salts
4( 1 H)-Pyrimidinone. 2.3-dihydro-6-methyl-2-lhioxo-
Pyrophosphoric acid, tetraethyl esier
Pyrrole, tetrahyaro-N-nitroso-
Quinoline
RADIOMUCLIDES
Reserpire
Resorcmol
Saccharin and sails
Safroie
Selenious acid
Selenium ft •
SELENIUM AND COMPOUNDS
Selenium dioxide
Selenium disulfide
Selenium oxide
Selenourea
L-Senne. diazoacetate (ester) ..
Slver n
[ SILVER AND COMPOUNDS
Silver cyanide
Silver nitrate
Silvex
Sodium
Sodium arsenate
Sodium arsenite ...
Sodium azide
Sodium bichromate
Sodium biftuonde .
Sodium bisulfite
Sodium chromato
Sodium cyanide
Sodium dodecyloenzene suifonale
Sodium tluonde
Sodium hydrosultide
Sodium hydroxide
Sodium hypochlorite
Sodium methyiate
Sodium nitrite
'21299
121211
8003347
504245
110861
91805
100754
109068
54115
56042
107493
930552
91225
'08463
81072
94597
7783008
7782492
7446084
7488564
7446084
630104
115026
7440224
506649
77S1888
93721
7440235
7631892
7784465
26628228
10588019
1333831
7631905
7775113
143339
25155300
7681494
16721805
1310732
7681529
10022705
124414
7632000
4.4 -stilbenediol alpha.alpna'-diethyl-
Streptozotocin
Strontium chromate
Strontium sulfide
Slrychnidin-tO-one. and salts
Slrvchnidm-10-one 2 3-dimethoxy- .
Strychnine and salts
Styrene
Sulfur hydride
Sulfur monochlonde
Sulfur phosphide
Sulfur selemde
Suilunc acid
50555 I Sulfunc acid dimethyl ester
Suifunc acid, thallium I) salt
24 5-T
2.45 -Tacid
2 4 5-T amines
2,4 5 r esters
2,4 5-T salts
TOE . . . . . .
1 2 4 5-ietrachiorobenzene
23,7.8-Tetracntorodibenzo-p-d.oxin(TCDO)
11.1 2-Tetrachloroeihane
112 2-Tetrachloroethane
Tetrachloroethylene
2.3.4,6-Tetrachlorophenol
iTetraethyldithiopyrophospnate
Tetraethyl lead
| Tetraethyl pyrophosphate
Tetrahydroruran
Tetranitronielhane
Tetraphosphonc acid, hexaethyl ester
Thallic oxide ...
IjThallium ft
• THALLIUM AND COMPOUNDS
Thallium(l) acetate
Thallium(l) carbonate
Thailium{l) chloride
Thallium) I) nitrate
lit-
56631
18883664
•;?!iS062
Vi',961
/ /D -.('64
\:-i' i"83
i'il-".03
-•48C1,64
7UVS39
801-1957
7/781
/4^0186
I DOT 1591
«3765
13765
2008460
6369966
6369977
1319728
S113147
93798
:'M5597
61 /92072
1 '.'JS478
f.'j168154
i:<'.W99t
'."J943
1^6016
'.'30206
,'9345
127184
58902
3^80245
78002
107493
109999
509148
757584
1314325
'""•0280
6W, 739
7781120
10102451
-------
OSWER DIR.9650.1
Hazardous Subatanc*
Thaittum(ill) oxide
Tnallium(l) selenid*
Thallium! I) surtote
Thioacetamide
Thiofanox .
Thioimidoaicaroonic diamide
Thtomethanol
Triioprwnol
Thiosemicarbaztde
Thiourea
Thiourea. (2,chtoroph«nyl)- - • •
Thiourea. 1 -naprnhalanyl-
Thiourea. phenyf-
Tniram . .
Toluene .
Tolueoediamme .
Toluene dnsocyanile
o-Toluidtne hydrochtonde
Toxaphene
2 4 5-TP acid
2 4 5-TP acid esters
1H-1 2.4-Triazol-3-amine
Tnchlorlon
1 2.4-Tnchlorobenzene
11,1 -Tnchloroethane
1 , 1 .2-Tnchloroethane
Tnchioroethene
Tnchloroeihylene
Tnchtoromethanesulfenyl chloride
Tnehloromonoftuoromethane . . . .
Tnchtorophenol
2.3.4-Tnchlorophenol
2.3.5-Tnchlorophenol
2.3,6-TncMorophenol
2.4,5-TncWoropnenol
2.4,6-Tncfilorophenol
3.4,5-Tnchloropnenol
2.4.5-Tncniorophenol
2.4.6-TncWorophend
2 4 5-Tncnloroplieno*yac»i«: acid . .
Tnethanolamme dodecyibenzenesulfonate
Tnethylamine
Tnmethylamine
sym-Tnmtrobenzene
1 ,3.5-Tnoxanu, 2.4 6-lnmsmyl- ..
Tns(2.3-dibromopropyt) phosptiate
Trypan blue
Unlisted Hazardous Wastes
Characteristic ot Ignitability
Characteristic ol Corrosivity
Charactenstic ot Reactivity
Characteristic ol EP Toxicity
Arsenic
Banum
CASRN
1314325
12039520
7446186
10031591
62555
39196164
541537
74931
108985
79196
62566
5344821
86884
103855
137268
108863
95807
25376458
496720
823405
584849
9VJ87
26471625
636215
8001352
93721
32534955
61825
52686
120821
71556
79005
79016
79016
594423
75694
25167822
15950660
933788
933755
95954
88062
609198
959S4
88062
93765
27323417
121448
75503
99354
123637
126727
72571
Hazardous SuMUnc*
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Endnn
Undane
Methoxycnlor
Toxaphene .
2.4-D
2.4 5-TP
Uracil. 5-(Dis(2-chloroethyl)amino|-
Uracil mustard
Uranyl acetate
Uranyl nitrate
Vanadic acid ammonium sail
Vanadium(V) oxide
Vanadium pentoxide
Vanadyl suilate
Vinyl acetate
Vinyl chloride
Vinylidene chloride
Wartann
Xylene (mixed)
m-
0-
P-
Xylenol
Vohimban-i6-cartxjxyiicacid.1i 1 7-aimetnoxy- 18-
[(3.4,5- mmeihoxyoenzoyi>oxy|-, methyiester
ZmctT
ZINC AND COMPOUNDS
Zinc acetate
Zinc ammonium chloride
Zinc berate .
Zinc bromide
Zinc carbonate
Zinc chlonde
Zinc cyanide
Zinc fluonde
Zinc tormate
Zinc hydrosulfite
Zinc nitrate . .
Zinc phenolsultonate
Zinc phosphide
Zinc silicofluonde
Zinc sultate
Zirconium nitrate
Zirconium potassium tluonde
Zirconium suifate
Zirconium tetrachionde
CASRN
66751
66751
541093
10102064
36478769
7803556
1314621
1314621
27774136
108054
75014
75354
31812
1330207
1 08383
95476
106423
1300716
50555
7440666
557346
52628258
14639975
14639986
1332076
7699458
3486359
7646857
55721 1
7783495
557415
7779864
7779886
127822
1314847
16871719
7733020
13746899
16923958
14644612
10026118
11 no reporting ot retoaae* of this hazardous suostance is required if diameter ot the pieces ol the solid metal released is equal to or exceeds 100 micrometers (0.004 inches)
111 the reoortable quantity lor asbestos la limited to triable forms only
-------
OSWER DIR.9650.1
APPENDIX F
F-l
-------
OSWER DIR.9650.1
Designation: G 57 - 78 (Reapproved 1984)"
Standard Method for
FIELD MEASUREMENT OF SOIL RESISTIVITY USING
THE WENNER FOUR-ELECTRODE METHOD1
ThU standard a issued under the fixed designation G 57. the number immediately following the designation indicates the
year of original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last
reapproval. A superscript epsilon (e) indicates an editorial change since the last revision or reapprovai.
" NOTE—Editorial changes were made throughout in September I984
1. Scope
1.1 This method covers the equipment and
procedures for the field measurement of soil
resistivity, both in situ and for samples re-
moved from the ground, for use in the control
of corrosion of buried structures.
1.2 This standard may involve hazardous ma-
terials, operations, and equipment. This standard
does not purport to address all of the safety prob-
lems associated with its use. It is the responsibil-
ity of whoever uses this standard to consult and
establish appropriate safety and health practices
and determine the applicability of regulatory limi-
tations prior to use.
2. Definition
2.1 resistivity—the electrical resistance of a
unit volume of a material: the reciprocal of con-
ductivity. Resistivity is used in preference to
conductivity as an expression of the electrical
character of soils (and waters) since it is expressed
in whole numbers.
2.1.1 Resistivity measurements indicate the
relative ability of a medium to carry electrical
currents. When a metallic structure is immersed
in a conductive medium, the ability of the me-
dium to carry current will influence the magni-
tude of galvanic currents and cathodic protection
currents. The degree of electrode polarization will
also affect the size of such currents.
3. Summary of Method
3.1 The Wenner four-electrode method re-
quires that four metal electrodes be placed with
equal separation in a straight line in the surface
of the soil to a depth not exceeding 5 % of the
minimum separation of the electrodes. The elec-
trode separation should be selected with consid-
eration of the soil strata of interest. The resulting
resistivity measurement represents the average
resistivity of a hemisphere of soil of a radius
equal to the electrode separation.
3.2 A voltage is impressed between the outer
electrodes, causing current to flow, and the volt-
age drop between the inner electrodes is mea-
sured using a sensitive voltmeter. Alternatively.
the resistance can be measured directly. The re-
sistivity, p, is then:
p.Q cm =» If aR(a in cm)
= 191.5 aR(a in ft)
where:
a = electrode separation, and
R = resistance, 12.
Using dimensional analysis, the correct unit for
resistivity is ohm-centimetre.
4. Apparatus
4.1 At-Grade Measurements in situ:
4.1.1 The equipment required for field re-
sistivity measurements to be taken at grade
consists of a current source, a suitable volt-
meter, ammeter, or galvanometer, four metal
electrodes, and the necessan wiring to make
the connections shown in Fig. 1.
4.1.2 Current Source —An a-c current
source is preferred since the use of a d-c
current will cause polarization of most metal
electrodes, resulting in error. The current can
be provided b\ either a cranked a-c generator
or a vibrator-equipped d-c source. An unal-
1 This method is under the jurisdiction of ASTM Com-
mittee G-l on Corrosion of Metals, and is the direct
responsibility of Subcommittee G01 10 on Corrosion in
Soils
Current edition approved March 31. 1978 Published
Mas 1978.
-------
OSWER DIR.9650.1
fib
tered d-c source can be used if the electrodes
are abraded to bright metal before immersion,
polarity is regularly reversed during measure-
ment, and measurements are averaged for
each polarity.
4.1.3 Voltmeter— The voltmeter shall not
draw appreciable current from the circuit to
avoid polarization effects. A galvanometer
type of movement is preferred but a moving
coil type of instrument will yield satisfactory
results if the meter resistance is in the order
of 100 000 fl/V.
4.1.4 Electrodes fabricated from mild steel or
manensitic stainless steel 0.475 to 0.635 cm (Vi6
to '/• in.) in diameter and 30 to 60 cm (1 to 2 ft)
in length are satisfactory for most field measure-
ments. Both materials may require heat treat-
ment so that they are sufficiently rigid to be
inserted in dry or gravel soils. The electrodes
should be formed with a handle and a terminal
for wire attachment.
4.1.5 Wiring, 18 to 22-gage insulated
stranded copper wire. Terminals should be of
good quality to ensure that low-resistance
contact is made at the electrodes and at the
meter. Where regular surveys are to be made
at fixed electrode spacing, a shielded multi-
conductor cable can be fabricated with termi-
nals permanently located at the required in-
tervals.
4.2 Soil Sample Measurement:
4.2.1 The equipment required for the mea-
surement of the resistivity of soil samples,
either in the field or in the laboratory, is
identical to that needed for at-grade measure-
ments except that the electrodes are replaced
with an inert container containing four per-
manently mounted electrodes (see Fig. 2).
4.2.2 If the current-carrying (outside) elec-
trodes are not spaced at the same interval as
the potential-measuring (inside) electrodes,
the resistivity, p, is:
p, n-cm = 95.76 bR
where:
b = outer electrode spacing, ft,
a = inner electrode spacing, ft, and
R = resistance, fl.
or:
p.n-cm -it- b
b + a,
where:
b = outer electrode spacing, cm
G57
a = inner electrode spacing, cm, and
R = resistance, fl.
4.2.3 The dimensions of the box can be
established so that resistivity is read directly
from the voltmeter without further calcula-
tion. The box should be readily cleanable to
avoid contamination by previous samples.
5. Field Procedures
5.1 At-Grade Measurements:
5.1.1 Select the alignment of the measure-
ment to include uniform topography over the
limits of the electrode span. Do not include
large nonconductive bodies such as frozen
soil, boulders, concrete foundations, etc.,
which are not representative of the soil of
interest, in the electrode span. Conductive
structures such as pipes and cables should not
be within Vz a of the electrode span unless
they are at right angles to the span.
5.1.2 Select electrode spacings with regard
to the structure of interest. Since most pipe-
lines are installed at depths of from 1.5 to 4.5 m
(5 to 15 ft), electrode spacings of 1.5, 3.0, and
4.5 m (5, 10, and 15 ft) are commonly used. The
a spacing should equal the maximum depth of
interest. To facilitate field calculation of resistiv-
ities, spacings of 1.58, 3.16, and 4.75 m (5.2,
10.4, and 15.6 ft), which result in multiplication
factors of 1000. 2000, and 3000, can be used
when a d-c vibrator-galvanometer instrument is
used.
5.1.3 Impress a voltage across the outer
electrodes, causing the current to flow. Mea-
sure the voltage drop across the inner elec-
trodes and record both the current and volt-
age drop if a separate ammeter and voltmeter
are used. Where a. resistivity meter is used.
read the resistance directly and record.
5.1.4 Make a record of electrode spacing,
resistance or amperes and volts, date, time,
air temperature, topography, drainage, and
indications of contamination to facilitate sub-
sequent interpretation.
5.2 Soil Sample Measurement:
5.2.1 Soil samples should be representa-
tive of the area of interest where the stratum
of interest contains a variety of soil types. It is
desirable to sample each type separately. It
will also be necessary to prepare a mixed
sample. The sample should be reasonably
large and thoroughly mixed so that it will be
representative. The soil should be well-com-
pacted in layers in the soil box, with air spaces
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OSWER DIR.9650.1
flb
eliminated as far as practicable. Fill the box
flush to the top and take measurements as
previously detailed (5.1.3). The meter .used
may limit the upper range of resistivity, which
can be measured. In such cases, the resistivity
should be recorded as <10 000 JJ-cm, etc.
5.2.2 The measured resistivity will be de-
pendent on the degree of compaction, mois-
ture content, constituent solubility, and tem-
perature. The effect of variations in compac-
tion and moisture content can be reduced by
fully saturating the sample before placing it in
the box. This can be done by preparing a stiff
slurry of the sample, adding only sufficient
water to produce a slight amount of surface
water, which should be allowed to evaporate
before the slurry is remixed and placed in the
box. Where available, use ground water from
the sample excavation for saturation. Other-
wise, use distilled water. If the soil resistivity
is expected to be below 10 000 fi-cm, local
tap water can be used without introducing
serious error. Some soils absorb moisture
slowly and contain constituents that dissolve
slowly, and the resistivity may not stabilize
for as much as 24 h after saturation. The
saturated measurement will provide a "worst-
case" resistivity, and can be usefulh com-
pared with "as-received" resistivity measure-
ments. Surplus water should not be poured
off as this will remove soluble constituents
5.2.3 Temperature correction will not be
required if measurement is made in-the-ditch
or immediately after the sample is taken. If
samples are retained for subsequent measure-
ment, correct the resistivity if the measure-
ment temperature is substantially different
from the ground temperature. Correction to
15.5*C (60*F) is recommended if the sample-tem-
perature exceeds 21'C (70T).
.5 + 7^
where:
T = soil temperature, °C, and
RT = resistivity at T °C.
A nomograph for this correction is shown in
Fig. 3.2
6. Planning and Interpretation
6.1 Planning:
6.1.1 Surveys may be conducted at regular
or random intervals. The former method is
suited to graphical presentation and plotting
G57
resistivity versus distance, and will identify
gradients and abrupt changes in soil condi-
tion. The latter method permits precise math-
ematical treatment, such as cumulative prob-
ability analysis. This method permits the de-
termination of the probability of the presence
of a soil with a resistivity equal to or greater
than a particular value.3 Where random resis-
tivities are measured over a plant site, these
can best be displayed on a plot plan or similar
layout. In either case, use pedological surveys
in the planning and interpretation of any
extensive survey. Measurements could be
made in each soil classification under a variety
of drainage conditions to simplify survey plan-
ning.
6.1.2 If resistivity information is required
to assess the requirement for corrosion con-
trol measures, it is recommended that the
tests be made on a true random basis. Since
the number of soil sections that could be
inspected is essentially unlimited, infinite
population characteristics can be used to sim-
plify statistical treatment. Risk and error must
be arbitrarily selected to allow determination
of the number of measurements. A risk of 5 %
of an error greater than 100 fi-cm should be
suitable for most situations. The error limit
should be about 10 % of the anticipated mean
resistiviu Where mean or median values
cannot be estimated with reasonable accu-
racy . sequential sampling techniques can be
employed..
6.2 Interpretation —Interpretation of the
results of resistivity suryeys will largely de-
pend on the experience 'of the persons con-
cerned. The mean and median resistivity val-
ues will indicate the general corrosivity of the
soil. Sharp changes in resistivity with distance
and appreciable variations in moisture content
and drainage are indicative of local severe
conditions. Cumulative probability plots will
indicate the homogeneity of the soil over the
area or route and will indicate the probability
of severe, moderate, and minimal corrosion
of the various construction materials. Availa-
ble pedological data should be used to facili-
tate interpretation.
7. Standardization
7.1 Periodically check the accuracy of re-
1 National Bureau of Standards Circular No 579, p 157.
' Scon. G. N.. "Corrosion. "National Association of Corrosion
Engineers, Vol 14. No. 8, August 1958.
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OSWER DIR.9650.1
sistance meters using a commercial resistance
decade box. Meter error should not exceed
5 % over the range of the instrument. If error
exceeds this limit, prepare a calibration curve
and correct all measurements accordingly. A
soil box can be calibrated using solutions of
known resistivity. Solutions of sodium chlo-
ride and distilled water with resistivities of
1000, 5000, and 10 000 ft-cm are recom-
mended for this purpose. These solutions
should be prepared under laboratory condi-
tions using a commercial conductivity meter.
itself calibrated to standard solutions at 20"C
(68°F).4
8. General
8.1 It should be recognized that subsurface
conditions can vary greatly in a short distance.
particularly where other buried structures
have been installed. Surface contamination
tends to concentrate in existing ditches with
surface run-off, appreciably lowering the re-
sistivity below the natural level. Since a pipe-
line ditch cannot be included in the span of
at-grade measurements, soil box samples
should be obtained where the opportunity
exists. To evaluate contamination effects
when a new route is being evaluated, soil
G57
samples can be obtained at crossings of exist-
ing pipelines, cables, etc, or by intentional
sampling using soil augers.
8.2 Other field resistivity measurement
techniques and equipment are available.
These commonly use two electrodes mounted
on a prod that is inserted in the soil-at-grade
in an excavation or a driven or bored hole.
The two-electrode technique is inherently less
accurate than the four-electrode method be-
cause of polarization effects, but useful infor-
mation can be obtained concerning the char-
acteristics of particular strata. More precise
procedures may be employed in laboratory
investigations and these should be defined in
reporting the results. Where resistivity infor-
mation is included in published information,
the measurement techniques used should be
defined.
9. Precision and Bias
9.1 Field measurement of soil resistivity using
the Wenner Four-Electrode Method is not avail-
able at this time. It will be included in the next
revision of this method.
4 Handbook of Chemistry and Phvsics. 41st ed.. The
Chemical Rubber Co., p. 2606
Potentiometer with
colibroted dial
Synchronous vibrator
Galvanometer—— , 1
'> / ' V,
L_^f\_'
MP~
> M
>
'
ft
~c'
1
lf
. p.
Bane
K
rt
i
i
|— ii'i —
ry B
C> o
*•
y \ ^
Current ^— Potential
electrode electrodes
• Sec.
I Power
' transformer
Push burton
a=b
V
Current
electrode
FIG. 1 Wiring Diagram for Typical d-c Vibrator-Current Source
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G57
OSWER DIR.96S0.1
Al UIIO WITH »FA*ATt AMMCTEK AND VOLTUETU
BATTXXr AMO CQNJAOLS
FIG. 2 Typical Coniwctiom for Use of Soil Box with Vtriom Typej of Instnimtnls
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OSWER DIR.9650.1
G57
L.
U
i
t—«
j u
EXAMPLE- GIVEN OBSERVED VALUES Of 80 OHMS
AND 56°F (13.3°C1. CONNECT THESE POINTS ON THE
OUTER SCALES WITH A STRAIGHT EDGE OR FINE
BLACK THREAD THE LINE INTERSECTS THE SCALE
FOR OHMS AT60°F (15.6°CI. AT 75 OHMS.
1-0
r:
FIG. 3 Nomogram or Conversion Chut for Reducing Soil Piste Resistance in ohms at a Particular Temperature as Measured in
the Bureau of Soils Cup, lo Resistance at 15.6'C (60*F)
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