4936
                                          510R87001
United States
Environmental Protection
Agency
Office of
Underground Storage Tanks
Washington, D.C. 20460
                                               January 1987
            Underground Storage Tanks
 oEPA
            Designing and Installing
            Underground Storage Tanks
            Under the New Federal Law
US,
Region V,Ubrary
230 South
Chicago, ,«Hnpit

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LEAKING  TANKS:
A  NATIONAL PROBLEM

    In   recent  years,   thousands   of   leaking
underground storage tanks  have been discovered
and  thousands more  probably  will  be  found.
Underground  tanks  containing  motor fuels  and
hazardous chemicals  are found  in many places,
including   service   stations,  transportation  and
delivery  services, manufacturing plants, and even
dry  cleaners.   Petroleum or chemical leaks from
underground tanks or pipes create environmental
and  safety hazards  and cost  tank  owners  and
operators a lot of money. For these reasons, proper
design  and installation  of  tanks  is  important to
prevent future damage to the nation's resources.
A TEMPORARY SOLUTION:
THE  INTERIM PROHIBITION

    In response to this situation, Congress passed a
law  regulating   underground   tanks   containing
petroleum  products or  hazardous chemicals.  The
U.S. Environmental Protection  Agency is studying
the leaking underground storage problem and,  in
1987, will  propose standards for  all new  and
existing  tanks and  regulations  for  leak detection,
prevention,  and corrective action.  Final standards
and regulations will be issued in 1988 after a period
of public comment.
   In the interim, the law requires that any tanks
and piping installed after  May 7, 1985 be designed,
constructed, and  installed to ensure prevention of
leaks. Called the "Interim Prohibition," this part of the
law bans bare steel tanks and requires controls for:

      H  Corrosion protection;

      •  Structural integrity; and

      •  Chemical compatibility


WHAT DOES ALL THIS  MEAN?

   This  brochure  explains  each    of  these
requirements and various ways to comply with them.
For those wanting more detailed  information, "The
Interim Prohibition:   Guidance  for Design  and
Installation of Underground Storage Tanks" can be
obtained by sending in the attached business reply
card.   Answers to  the  most   frequently  asked
questions about the Interim Prohibition are provided
on the back of this brochure.

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CORROSION:
WHAT YOU CAN DO ABOUT IT

What is Corrosion?

    The  external surface of a steel  tank, when it
comes in contact with the soil, will naturally seek to
return to  its original state, iron oxide, or the more
commonly known term, rust.  This  is a  complex
electrochemical process that creates a flow of current
between  two  materials  with  different  electrical
characteristics.  Metal corrodes under almost any
naturally  occurring soil condition, but  the  rate of
corrosion is affected by the amount of  oxygen and
moisture in the soil and other site-specific factors.

How Can Corrosion Be Controlled?

    The  Interim  Prohibition identifies three different
methods of corrosion control:

    «  Cathodic protection;

    *  Noncorrosive materials of construction; (i.e.,
       fiberglass reinforced plastic) and,

    *  Noncorrosive coating of steel.

    The  Interim  Prohibition  also allows the use of
other corrosion controls if "...they are designed in a
manner to prevent the release or threatened release
of  any   stored  substance."   Regardless  of the
technology chosen, corrosion protection is required
for both the piping and the tank.

    Cathodic Protection

    Cathodic  protection  reverses  the   electrical
forces that cause corrosion and  can be achieved in
two ways:

    a  Connecting zinc or magnesium anodes to a
       steel tank, (sacrificial anode system); or

    "  Applying a continuous electrical current to
       the tank (impressed current system).

    You  can check  the effectiveness of either of
these systems by measuring voltage  between the
tank and the soil.  In both systems  this voltage must
be checked periodically for damage requiring repaifs.

    Galvanized (zinc coated) pipe was developed
and is effective for above ground use.  However, it
does   not  satisfy   EPA's  Interim  Prohibition
requirements    for    corrosion    protection   of
underground storage tanks because  zinc  coating
only provides a limited amount of protection.

    Noncorrosive Materials of Construction

    The Interim Prohibition allows tanks and piping to
be  constructed  of noncorrosive materials  as  an
alternative to cathodic protection.  The most widely
used  noncorrosive material in the  manufacture of
tanks  and  piping  is fiberglass  reinforced  plastic
(FRP). Tank systems constructed of FRP satisfy the
corrosion  protection  requirements  of the  Interim
Prohibition.   It  is the only material  that contains
sufficient  corrosion resistance  without  additional
cathodic protection or coating.

    Noncorrosive Coating

    Another type of protection that complies with the
Interim Prohibition is a steel  tank  coated with
fiberglass reinforced plastic. There is some debate
among corrosion  control  experts  regarding  the
advisability  of using  any coating without cathodic
protection;  however, the Interim  Prohibition  allows
the use of "steel clad with a noncorrosive material."
Only  FRP-coated steel  is  acceptable.   The  key
factors in the success of this coating include  its
thickness, insulating strength, durability, and good
bonding  to  the  steel.   Manufacturers'  standards
currently require:

   m   A minimum thickness of completed coating
       equal to 0.10 inch; and

   *   Electric testing to ensure complete coating
       of the tank.

    These   should  be   considered   minimum
standards for  acceptability of  fiberglass  reinforced
plastic coatings.   As consensus codes  or other
national  standards become  available, they  may
supplement or replace these minimum standards.

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                                                           :r

United States Environmental
Protection Agency

Office of Underground Storage
Tanks (OUST), WH - 562A
Washington, DC 20460
Bulk Rate
U.S. Postage
PAID
Rockville, MD
Permit No. 5032

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STRUCTURAL  INTEGRITY:
PROPER  INSTALLATION IS
CRUCIAL
    The Interim Prohibition requires that tanks be
properly installed so structural failure does not occur.
One of the keys to achieving this is proper selection
and installation of the backfill material used to support
the tank. For fiberglass reinforced plastic tanks, the
backfill provides as much as 90 percent of the tank's
support. For both  steel and fiberglass tank systems,
failure  to  properly backfill the  tank can  cause
structural damage  and result in contamination of soil
and ground water, and serious liability.

    Tank   manufacturers    provide   installation
instructions which  should be strictly followed.  Many
states   and  local  jurisdictions   have  additional
requirements which tank owners and installers also
must  follow.   Check with your fire,  health,  and
environmental agencies for requirements.

    The EPA's guidance  document  is  limited in
scope.  A manual covering   all  aspects  of  tank
installation  has recently  been developed  by  the
Petroleum      Equipment     Institute      (PEI),
"Recommended   Practices   for   Installation   of
Underground  Liquid  Storage  Systems."    Single
copies of PEI  RP 100-86 cost  $10.00 ($8.00 for PEI
members).  Quantity discounts  are available for 25 or
more   copies.    Order  prepaid  from: Petroleum
Equipment  Institute,  P.O.  Box 2380,  Tulsa,  OK
74101.
                                 The American Petroleum Institute (API) also has
                             a booklet of recommended practices, "Installation of
                             Underground Petroleum Storage Systems" (#1615),
                             published  in  1979.  It can be  purchased for $4.00
                             from  API,  1220 L  Street,  NW, Washington,  D.C.
                             20005.
                             COMPATIBILITY: WILL YOUR
                             PRODUCT DISSOLVE YOUR
                             TANK'S INTERIOR?
                                 The liquid stored in a tank must not dissolve the
                             material of the tank's interior or coating. Some stored
                             liquids do; this  is called  chemical incompatibility.
                             Incompatibility can result in cracks  and openings in
                             the tank that allow chemicals to seep into the soil.
                             Common   examples   of    chemicals   that   are
                             incompatible with specific  types of tank  liners and
                             construction materials are:

                                 Mineral acids including nitric, hydrochloric, and
                                 dilute sulfuric acids which are incompatible with
                                 steel.

                                 Sulfuric acid (95 percent), nitric acid (50
                                 percent), hydrofluoric acid (40 percent),
                                 aromatic solvents, and chlorinated solvents
                                 which are incompatible with some types of
                                 fiberglass reinforced plastic.

                                 Organic solvents which are incompatible with
                                 chlorinated rubber liners.

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ANSWERS TO QUESTIONS ABOUT THE INTERIM PROHIBITION
Q.
A.
Q.
A.
Q.
A.
Q
   How will the proposed regulations affect a tank designed and installed in compliance with the Interim
   Prohibition?
   The regulations, as proposed, are the same as the Interim Prohibition Standards for new tanks, but will also
   include regulations for leak detection and reporting, corrective action, and financial responsibility. Tank
   owners and operators should read the final regulations very carefully so they will know what they must do to
   comply with them.

   Are any classes of tanks entirely exempt from the Interim Prohibition?
   Yes. Tanks that are specifically exempt include tanks storing heating oil foruse on the premises,
   residential and farm tanks storing motor fuels if the tank volume is 1,100 gallons or less, and tanks whose
   volume (including piping) is less than 10 percent beneath the surface of the ground.

   Is a tank installed in noncorrosive soil exempt from the corrosion protection requirement of the Interim
   Prohibition?
   Possibly.  If soil tests conducted in accordance with ASTM Standard G57-78 show that soil resistivity is
   12,000 ohm/cm or more, a storage tank without corrosion protection may be installed. The tank must still
   comply with the structural integrity and compatibility requirements of the Interim Prohibition.
   Are double-walled tanks, lined tanks, or tanks with other secondary containment systems exempt from the
   corrosion protection requirements of the Interim Prohibition?
A. No.

Q. Does the Interim Prohibition apply to "recycled" tanks?
A. Yes. A tank that is removed and reinstalled at the the same or another location is subject to the Interim
    Prohibition.

Q. What is the penalty for noncompliance with the Interim Prohibition?
A. The maximum penalty is $10,000 per tank for each day of violation.

Q. How can I obtain more information?
A. You can call the EPA toll free Hotline at (800) 424-9346 or direct at (202) 382-3000. To receive the Interim
   Prohibition Guidance Document and be put on the mailing list for copies of EPA's proposed regulations
   and other information, return the attached card.
    BUSINESS REPLY MAIL
    FIRST CLASS PERM IT NO. 1566 ROCKVILLE, MD.
    POSTAGE WILL BE PAID BY ADDRESSEE

    U.S. Environmental Protection Agency
    Office of Underground Storage Tanks
    Box 6044
    Rockville, MD 20850
                                                    NO POSTAGE
                                                    NECESSARY
                                                     IF MAILED
                                                       IN THE
                                                   UNITED STATES
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                                                      U.S. Environmental Protection Agency
                                                      Region  V,  Library
                                                      230 South Dearborn Street
                                                      Chicago, Illinois'  60604
                                                                      I

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