vvEPA
          United States
          Environmental Protection
          Agency
           Office of
           Underground Storage Tanks
           Washington, D.C. 20460
April 1987
Proposed Regulations for
Underground Storage Tanks
         What's In The Pipeline?

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                                  Acknowledgement



The text of this brochure was prepared by Jay Evans for EPA's Office of Underground Storage Tanks.

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What's In The Pipeline?
Why Is EPA Proposing These New Regulations?	1
How Will These Proposed Regulations Affect You?	1
What's an UST?	2
Why Do USTs Leak?	3
Are Leaks The Only Problem?	3
What Requirements Will All New USTs Need To Meet?	4
What Requirements Will Apply To Existing Petroleum USTs?	4
What Do You Do When Leaks Or Spills Happen At Your Petroleum UST?	6
Can Leaking Tanks Be Repaired?	7
How Can You Take Tanks Out Of Service?	7
What's Your "Financial Responsibility" For Petroleum Leaks?	8
How Do You Keep Track Of All This?	8
Will The Final Regulations Differ From The Proposed Regulations?	9
What Other Requirements Should You Be Aware Of?	9

For Chemical USTs Only
What Chemicals Are "Hazardous"?	11
What Additional Requirements Are There For New Chemical USTs?	11
Are There Any Exceptions To These Additional Requirements For New Chemical USTs?	12
How Can You Get A "Variance" From  The New Chemical UST Requirements?	12
What Requirements Will Apply To Chemical USTs Already In The Ground?	12
What Do You Do If You Have A Chemical Leak Or Spill?	13
Will Owners And Operators Of Chemical USTs Need To Show "Financial Responsibility"?	13

Technical "Questions & Answers"	15

How Can You Get More Information?	18

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What's In The Pipeline?
                                                                   REGULATIONS
                                       u
The U.S. Environmental Protection Agency (EPA)
has recently proposed regulations for many of the
nation's underground storage tanks.  Although the
complete proposal appears in the Federal
Register (April 17,1987), this brochure briefly
describes the proposed technical requirements.
Comments from the general public will be
considered before EPA issues final regulations
early next year.


Why Is EPA Proposing

These  New  Regulations?

Several million underground tanks in the United
States contain petroleum or hazardous chemicals.
Thousands of these underground storage tanks
-often called USTs-are currently leaking. Many
more are expected to leak in the future. Leaking
USTs can cause fires or explosions that threaten
human safety.  In addition, leaking USTs can
contaminate nearby ground water. Because many
of us depend on ground water for the water we
drink, Federal legislation seeks to safeguard our
nation's ground-water resources (see map on
page 2).

Congress responded to the problem of leaking
USTs when, in 1984, it added Subtitle I to the
Resource Conservation and Recovery Act.
Subtitle I requires EPA to develop regulations to
protect human health and the environment from
leaking USTs.
How Will These Proposed
Regulations Affect You?

The proposed regulations describe the steps you
--the tank owner or operator-may have to take to
help protect our drinking water resources. These
steps will also help you avoid the high cost of clean-
ing up the environment and settling legal suits that
can result if your tank leaks.

There are four major points you should note:

• Final regulations are not far off. EPA will issue
  them in early 1988.  Until then, all new USTs must
  meet the requirements of the Interim Prohibition
  described below.

• Within 3 to 5 years after the regulations become
  final, your USTs will have to meet leak detection
  requirements.

• Within 10 years, your USTs must also be
  protected from corrosion and equipped with
  devices to prevent spills or overfills.

• You will be financially responsible for the cost
  of cleaning up a leak and compensating other
  people for bodily injury and property damage
  caused by your leaking tank.

These points are discussed in the following sec-
tions.  Additional detailed explanations appear on
page 15  in the technical "Questions & Answers"
section.

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What's an "UST"?
• Tanks storing heating oil burned on the premises
  where it is stored.
An UST is any tank, including any underground
piping connected to the tank, that has at least 1 0
percent of its volume below ground. The proposed
regulations will apply only to USTs storing either
petroleum or certain hazardous chemicals.

The requirements for both petroleum and chemical
USTs are basically the same. However, please note
that additional requirements for chemical USTs are
described separately on page 1 1 in the "For
Chemical USTs Only" section.

Some kinds of tanks are not covered by these
regulations:

• Farm and residential tanks holding less than
  1 ,100 gallons of motor fuel used for non-
  commercial purposes.
• Tanks on or above the floor of underground
  areas, such as basements or tunnels.

• Septic tanks and systems for collecting storm
  water and waste water.

• Flow-through process tanks.

Other storage areas that might be considered
"tanks" are also excluded, such as surface im-
poundments and pits. The proposed regulations
published in the Federal Register include
detailed definitions of these and other terms used
in the UST regulations.
                     Estimated Ground Water Use By States
                                                                              50% or more

                                                                              30% to 49%

                                                                              Less than 30%

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Why  Do USTs Leak?
No Corrosion Protection

Most of the USTs already in the ground are made of
bare steel. When steel is buried in the ground, it
can be eaten away by corrosion. However, bare
steel USTs can be protected from corrosion by two
forms of "cathodic" protection:  "sacrificial anode"
and "impressed current"  protection systems.
(These terms are explained in  the technical
"Questions & Answers" section.)

Steel USTs can also be protected from corrosion if
they are coated with a material, such as fiberglass-
reinforced plastic, that will not corrode. Another way
to avoid the problem of corrosion is to build the
entire tank of a noncorrodible material.
Installation Mistakes

Tanks and piping also leak if they are not put in
the ground properly.  For example, if poor backfill
material is used when covering the UST or if pipe
fittings are inadequately attached to the UST, then
leaking often results. These mistakes made during
installation can be avoided by having the installer
follow approved installation procedures.  (Approved
installation procedures are referenced in the tech-
nical "Questions & Answers" section.)
Piping Failures

EPA studies show that many leaks result from
piping failure.  In fact, piping fails more often than
tanks.  Because piping is smaller and less sturdy
than tanks, it may be more likely to suffer from
installation mistakes and the effects of corrosion.
It is important to remember that the proposed
regulations will apply to the entire UST system--
both tanks and piping.
Are Leaks The Only

Problem?

In addition to leaks from tanks and piping, the
UST can be the site of another type of accidental
release: spills and overfills. These spills are usually
the result of human error and can be avoided by
following correct tank filling practices. Mechanical
devices, such as overfill alarms, also reduce spills
and overfills.

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What Requirements
Will All New USTs
Need To Meet?
                                                                                     7\
The proposed regulations create four minimum
requirements for all new USTs:

• The owner or operator must certify that the UST
  is installed properly. (EPA is developing materials
  that will help with that task.)

• The UST must be protected from corrosion.
  A steel UST must be "cathodically" protected,
  as described above, and coated with a corrosion-
  resistant coating. Other USTs must be made
  totally of a noncorrodible material or of a compo-
  site of steel and noncorrodible material.

• The UST must be equipped with devices that
  prevent spills and overfills. Also, correct tank
  filling practices must be followed.

• The UST must have a leak detection method that
  provides monitoring for leaks at least every 30
  days.

(Additional requirements for new chemical USTs
are described in the "For Chemical USTs Only"
section.)

A leak detection method must be able to detect a
leak in any part of the UST, including the piping.
Leak detection can consist of one or a combination
of the following methods:

•  Tank tightness testing (twice yearly) and
   inventory control (measured daily).

•  Automatic monitoring of product level and
   inventory control.

•  Monitoring for vapors in the soil.

•  Monitoring for liquids in the ground water.

•  Monitoring an interception barrier.

•  Interstitial monitoring within secondary
   containment.
•  Other methods approved by EPA.

(These methods are described in the technical
"Questions & Answers"  section and illustrated
in the chart on page 5.)

When you use methods such as soil or
ground-water monitoring-which are external
leak detection methods~a site assessment must
be performed so that they can be properly applied
to the  particular site.
What Requirements
Will Apply To Existing
Petroleum USTs?
The goal of the proposed regulations is--overthe
next 10 years-to improve petroleum USTs already
in the ground so that they will meet the more dem-
anding requirements for new USTs, as described
above. (Requirements for chemical USTs already
in the ground are described in the "For Chemical
USTs Only" section.)
What All Existing Petroleum USTs Must
Be Like In 10 Years

At the end of this 10-year period, all USTs in the
ground now will need to show three required
improvements:

• They must meet the same requirements for
  corrosion protection that apply to new USTs.

• They must meet the new UST requirements for
  having a leak detection method.

• They must be equipped with devices that
  prevent spills and overfills.

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                                LEAK  DETECTION  METHODS
                  CONCRETE
         OVERFILL
           DEVICE
    1 -TANK  TIGHTNESS  3 - VAPOR MONITORING  5 - INTERCEPTION BARRIER  7 • OTHER METHODS
       TESTING
IN  THE SOIL
    2 • IN TANK MONITOR  4 - GROUND-WATER
                           MONITORING WELL
                    6 - DOUBLE-WALL  TANK
                       WITH  INTERSTITIAL
                       MONITOR
APPROVED
BY EPA
Leak Detection Requirements During The
10-Year Period

Certain leak detection requirements apply before
this 10-year period ends. These requirements
differ for USTs not protected from corrosion (bare
steel) and those that are protected from corrosion
(all others).

Because bare steel USTs are the most likely to leak,
they must have a leak detection method within 3
years. Tanks that are already protected from corro-
sion must have a leak detection method within 5
years. The same leak detection methods noted
above for new tanks will meet the leak detection
requirements for existing USTs.
                         Because it would be very difficult-within 10 years
                         -for all USTs already in the ground to have the leak
                         detection methods noted above, another method
                         can temporarily satisfy the leak detection require-
                         ment.  This method allows a combination of daily
                         inventory control and periodic tank tightness
                         testing. The amount of time between tests varies,
                         again depending on whether the tank is protected
                         from corrosion. Bare steel tanks must be tested
                         every 3 years. Protected tanks must be tested
                         every 5 years.

                         Please note, however, that this method is allowed
                         only during the 10 years following the publication
                         of the final regulations. After that, all USTs must
                         meet the leak detection requirements for new
                         USTs.

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                                    Existing  Petroleum  Tanks

                                Minimum Leak  Detection  Requirements
                                         Use Dally Inventory Control
                                                   Plus
                                    Bare Steel               Protected From Corrosion
                     Tank tightness
                       test within
                        3_years
                                                                             1
                                                          Tank tightness
                                                           test within
                                                            5 years
                   (no leak)    (leak)
                                                        (no leak)    (leak)
Test in
3 years
                                                                   Test in
(no leak)  fr  (teak) w
                           Repair
                        (one time only);
                         test in 1 year
                                                               (no leak)
                                                          (leak)
Test in
3 years
               (no leak)
   Repair
(one time only);
 test in 1 year
             (leak)
                    (if year 10)
                                Year  10
                      MUST MEET NEW TANK STANDARDS
                    (e.g., Corrosion Protection and Leak Detection)
                                                              (if leak, or year 10)
                                    (Simplif ed -- Does not reflect all requirements)
No matter which of the above leak detection
methods you use, they must be working by the
deadlines described above (3 years for bare steel
USTs; 5 years for protected USTs). If not, you must
close or upgrade your tank.

The chart above illustrates the minimum
requirements for interim leak detection using
daily inventory control plus tank tightness testing.
What Do You Do When Leaks
Or Spills Happen At Your
Petroleum UST?

Under the proposed regulations, your response to
a petroleum leak or spill would appear in two stages:
Immediate and long-term.
                                    Five Immediate Steps

                                    1. Tell the regulatory authority within 24 hours that
                                       there is a leak or spill. The only exception is for
                                       aboveground petroleum spills and overfills of
                                       less than 25 gallons. These small spills do not
                                       have to be reported if they are immediately
                                       contained and cleaned up.

                                    2. Take immediate action to stop the leak or spill
                                       and make sure it poses no hazard to human
                                       health and safety.

                                    3. Remove any visibly contaminated soil.

                                    4. Report your actions to the regulatory authority
                                       no later than 20 days after a leak is confirmed.

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5. Conduct a complete site investigation to deter-
   mine the extent of the leak and how much it has
   damaged nearby soil and ground water. Within
   30 days of confirming a leak, you must submit a
   plan for removing leaked petroleum, if it has
   been detected in the ground water.

These immediate actions are required for all petro-
leum leaks or spills, but some leaks will require
long-term attention to correct the problem.
Two Long-Term Steps

In long-term cases, the site must be cleaned up to
meet environmental requirements established at
each site by the regulating authority.

1. Develop a Corrective Action Plan~an officially
   approved plan for cleaning up your site-that
   shows how you will meet cleanup requirements
   established at your site by the regulating
   authority.

2. Make sure you  meet the cleanup requirements
   approved by the regulatory authority for your
   site.
Can Leaking Tanks Be
Repaired?

You can repair a tank only once.

Damaged piping cannot be repaired and must be
replaced.

The proposed regulations set minimum standards
for tank repair; for example, an open seam more
than 3 inches long cannot be repaired. These
minimum standards follow codes used by the tank
industry. The tank must pass special vacuum and
ultrasonic tests proving that the tank is repairable
and that repairs are conducted correctly.
Also, when a tank is repaired, corrosion protection
must be added and a coating must be applied to the
inside of the tank.
How Can You Take Tanks Out
Of Service?

You may decide to close your LIST temporarily or
permanently. Any tank not used for over 3 months
must follow four requirements for temporary
closure:

• You must maintain corrosion protection systems
  at the tank.

• You must continue to operate a leak detection
  method to identify leaks. If a leak is found, you will
  have to respond just as you would for a leak from
  an active UST, as described above.

• You must cap all lines, except the vent line,
  attached to the UST.

• You must notify the regulatory authority of your
  actions.

If your tank remains closed for more than 2 years,
then you must follow the requirements for
permanent closure:

• You must determine if your tank has damaged the
  surrounding environment. If there is damage,
  then you will have to follow the corrective action
  steps described above.

• You can either remove the UST from the ground
  or leave it in the ground. Before taking the UST
  out  of the ground, you must remove all liquids,
  vapors, and pipes from the UST.  If you leave the
  UST in the ground, then you must remove all
  liquids and pipes from the tank and fill it with a
  harmless, chemically inactive solid, like sand.

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What's Your "Financial
Responsibility" For
Petroleum Leaks?
Owners or operators of petroleum USTs must
be able to demonstrate-at any time--their ability to
pay for damage that could be caused if their tanks
leaked. These payments would need to cover the
costs of cleaning up a site (as described above) and
compensating other people for bodily injury and
property damage.

The minimum coverage for each facility is $1 million.
The more tanks you have, the greater the risk, and
the more coverage you must have.  The maximum
coverage  required is $6 million.

You can use one or a combination of several
mechanisms to meet your financial  responsibility:
insurance, guarantees, indemnity contracts, risk
retention groups, surety bonds, letters of credit,
and state-assured mechanisms.

A complete explanation of these financial respon-
sibility requirements appears in another EPA
brochure, "Proposed Regulations for Underground
Strorage Tanks: Your Financial Responsibilities."
If you want to study these proposed financial
responsibility requirements  in detail, see the
Federal Register  (April 17,1987).  Congress
has also created a Trust Fund that EPA or states
can use to clean up sites meeting certain require-
ments.
 How Do You  Keep
 Track Of All This?


RECORDKEEPING /


























A
You will need to be able to show the regulatory
authority a written record of four major activities at
your UST:

• Leak Detection Method. You will have to
  keep records for 5 years of any manufacturers'
  claims of how well their leak detection devices will
  perform. You will need to keep monitoring results
  for the past 12 months. Tank tightness test
  results  must be kept until the tank is tested again.

• Corrosion Protection System.  If your pro-
  tection system was applied at a factory, the last
  service check conducted under the tank warranty
  must be kept. If the system was applied "in the
  field," then reporting periods depend on the
  type of protection system installed. For the "im-
  pressed current" type, the results of the last three
  inspections and two annual service readings must
  be kept;  for the "sacrificial  anode" type, the last
  two annual service readings must be kept.

• Tank Repair. As long as you use a repaired
  tank, you must keep records that show that the
  tank was properly repaired  and passed ultrasonic
  and vacuum tests.

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• Closing an UST. For at least 1 year, you must
  keep a record of the test results required for tem-
  porary closure.  For at least 3 years, you must
  keep a record of the test results required for
  permanent closure. (These test results show
  what impact your UST has had on the
  surrounding area.)

Generally, you should follow this useful rule of
thumb for recordkeeping: When in doubt, keep it!
What Other
Requirements Should
You Be Aware Of?
Congress established two other requirements that
are already in place regarding USTs: the "Interim
Prohibition" and "Notification."
Will The Final

Regulations Differ

From The Proposed

Regulations?

The complete proposal explains a number of
options EPA considered. For example, one option
required "secondary containment" at all new petro-
leum USTs.  Secondary containment adds a second
wall between the UST and the surrounding environ-
ment. Another option identified certain locations
where more stringent requirements should apply
because of the danger those sites pose to nearby
ground water. Those sites needing maximum pro-
tection would be required to use secondary con-
tainment.  Those needing less protection could
use a single-walled system. EPA will continue to
consider a variety of options as it develops final
regulations for USTs.
The Interim Prohibition

Since May 1985, any UST being installed in the
ground must meet minimum requirements:

• The UST must prevent releases due to corrosion
  or structural failure.

• The stored contents must be compatible with the
  tank's interior wall.

(See 40 CFR Part 280 for a complete explanation
of the "Interim Prohibition." Also, you can refer to
the EPA document, "The Interim Prohibition:
Guidance for Design and Installation of Under-
ground Storage Tanks.")
Notification

If you have an UST already in the ground or if you
are installing one, you must notify a State agency
of that tank's existence. (See Federal Register
of November 8,1985 for a complete explanation
of the "Notification" requirements. EPA can also
supply you with a "List of Agencies Designated to
Receive Notifications.")

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For Chemical
USTs Only
                 HAZARDOUS
                 CHEMICALS
What Chemicals Are
"Hazardous"?

A number of chemicals were designated as
"hazardous" in Section 101 (14) of the Compre-
hensive Environmental Response, Compensation,
and Liability Act of 1980, better known as CERCLA
or "Superfund".  With one exception, the proposed
UST regulations apply to the same hazardous
chemicals identified by CERCLA.

The exception concerns substances that are
hazardous wastes, which are already regulated
under Subtitle C of the Solid Waste  Disposal Act.
Therefore, these hazardous wastes are not
covered by the proposed UST regulations.
(See 40 CFR Parts 260-270 for the  hazardous
waste regulations.)

A list of the CERCLA hazardous chemicals is avail-
able from EPA through the Hotline (800-424-9346).
Although this list contains discarded commercial
chemical products, the proposed UST regulations
would cover only those hazardous chemicals on the
list that are not discarded or in the process of being
discarded as wastes.

If an UST contains both petroleum and hazardous
chemicals, it will be regulated as a chemical UST if
the principal part of the stored mixture is made up of
hazardous chemicals.
What Additional Requirements
Are There For New  Chemical
USTs?

In addition to the proposed requirements for new
petroleum USTs described earlier, chemical USTs
would need to satisfy the following requirements for
"secondary containment" and "interstitial monitoring.'


Secondary Containment

All new chemical USTs must have "secondary
containment." The UST itself makes up the first
or "primary" containment. Using only primary
containment, a leak can escape into the environ-
ment. By enclosing an UST within a second wall,
leaks can be contained in a relatively small and
controllable area.

There are several ways to construct secondary
containment:

• Placing one tank inside another tank (making
  them double-walled tank systems).

• Placing the tank inside a concrete vault.

• Lining the excavation area surrounding the tank
  with natural or synthetic liners that cannot be
  penetrated by the chemical.
                                                                                         11

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Interstitial Monitoring

The chemical LIST must have a leak detection sys-
tem that can indicate the presence of a leak in the
confined area between the primary and secondary
walls.  Several devices are available to monitor this
confined "interstitial" area. The proposed regula-
tions describe these various methods and the
requirements for their proper use.
What Requirements Will Apply
To Chemical USTs Already In
The Ground?

The goal of the proposed regulations is--overthe
next 10 years--to improve chemical USTs already in
the ground so that they will meet the requirements
for new chemical USTs, as described above.
Are There Any Exceptions
To These Additional
Requirements For New
Chemical USTs?

You can apply for an exception, called a variance,
from the requirements for secondary containment
and interstitial monitoring. This variance will be
granted only if the chemical UST meets the
following requirements:

• A leak detection method must be available for the
  stored chemical.  The leak detection method
  must meet the same general requirements for
  leak detection discussed earlier.

• USTs made of one wall only (single-walled USTs)
  must be protected from corrosion.

• All pressurized piping not provided with inter-
  stitial or continuous monitoring must have an
  emergency cutoff pressure monitor.
 How Can You Get A "Variance"
 From The New Chemical UST
 Requirements?

 The regulatory authority can grant a variance after
 reviewing your request. You will have to satisfy the
 regulatory authority that your leak detection system
 will work effectively for the substance stored in the
 tank.  EPA is working on guidance to assist in the
 development and review of variance applications.
What All Existing Chemical USTs Must Be
Like In 10 Years

At the end of this 10-year period, all chemical USTs
in the ground now will need to show these required
improvements:

• They must meet the same requirements for sec-
  ondary containment and interstitial monitoring
  that apply to new chemical USTs. As with new
  chemical USTs, a variance can be granted for
  single-walled USTs protected from corrosion
  and equipped with an approved leak detection
  method.

• They must be equipped with devices that prevent
  spills and overfills.
Leak Detection Requirements During The
10-Year Period

Certain leak detection requirements apply before
this 10-year period ends. These requirements are
the same as those described earlier for petroleum
USTs already in the ground.  However, the leak
detection methods noted for petroleum USTs can
be applied to your chemical UST only if those
methods work with the stored chemical. If an effec-
tive leak detection method is not in place  by the
deadlines described earlier (3 years for bare steel
USTs; 5 years for protected USTs), you would have
to close or upgrade your UST. The chart  on the
next page illustrates these interim leak detection
requirements.
12

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Existing Chemical Tanks
Minimum Leak Detection Requirements
Bare Steel ^ Protected from Corrosion



Does tank tightness Does tank tightness
testing work? testing work?
(yes) i
+
Use daily inventory
control plus test tank
within 3 years
(no leak) ^ (leak)
i
Test in f — »
r (no) (no)
+ 1
Within 3 years, Within 5 years,
install secondary install secondary
containment containment

*
' 	 T>-t
3 years Repair 5 ye
(no teak) | (teak) *Z™™ (no leak) |


_,
Test in ^ (no leak) u (

| (if year 10)

1
t
Year 10
eak)
(Secondary containment with interstitial
^ monitoring or have approved variance)

(Simplified - Does not reflect all requirements.)
^ (yes)
i
Use daily inventory
control plus test tank
within 5 years
(no leak) | (teak)

in "
ars RePaif
	 7fiak) (one time only);
( L+ »««t '" 1 yw

(if leak, or year 10)

What Do You Do If You Have A
Chemical Leak or  Spill?

You would follow the same immediate and long-
term steps described earlier for petroleum leaks
and spills-except for the following important
difference. You have to report all aboveground
chemical leaks or spills, unless they are smaller
than the "reportable quantities" identified under
CERCLA and they are immediately contained
and cleaned up.
Will Owners And Operators Of
Chemical USTs Need To Show
"Financial Responsibility"?

Yes. EPA will later propose separate financial
responsibility requirements for chemical UST
owners and operators.
                                                                                  13

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Technical
"Questions & Answers"
                                                                      TECHNICAL
                                                                    Qs  &  As
       How does "corrosion" cause USTs
to leak?  How can USTs be protected from
corrosion?
A
       Corrosion attacks unprotected steel USTs
mainly through "galvanic" corrosion. When this
happens, the tank and its underground surroundings
act like a battery. Part of the tank can become nega-
tively charged and another part positively charged.
Various soil conditions provide the connecting link
that finally turns these LIST "batteries" on. Then, the
negatively charged part of the tank-where the current
exits from the tank-begins to deteriorate. As electric
current passes through this part, the hard metal
begins to turn into soft ore, holes form, and the
tank leaks.

Bare steel USTs can be protected, however, by
reversing the electrical circuit causing the corrosion.
This "cathodic protection" comes in two forms:

• "Sacrificial anodes" can be attached to the UST.
  Sacrificial anodes are pieces of metal more elec-
  trically active than the steel UST. Since these
  anodes are more active, the electric current will
  exit from them rather than the tank.  Thus, the
  "cathode" of the tank remains protected and free
  of corrosion while the attached "anode" is
  sacrificed.

• An "impressed current" protection system
  introduces an electric current into the ground
  through a series of anodes not attached to the
  UST.  Because the electric current flowing from
  these anodes to the tank system is greater than
  the corrosive current flowing away from the tank,
  the UST is protected from galvanic corrosion.

  Steel USTs can also be protected from corrosion if
  they are adequately coated by a noncorrodible
  material, such as fiberglass-reinforced plastic.
For more information on how corrosion works and
how USTs can be protected from corrosion, see the
Preamble of the proposed regulations (Sections
III.B.1;  III.C.1; VI.C.2) or the proposed rule (Subpart
B, 280.20; Subpart C, 280.31). A comprehensive
discussion of corrosion and corrosion-protection
methods appears in EPA's "The Interim Prohibition:
Guidance for Design and Installation of Under-
ground Storage Tanks" (EPA/530-SW-85-023;
August 1986).
                                                    Q
       What are "installation mistakes"
and how can they be avoided?
                                                           Improper installation is a significant cause
                                                    of fiberglass-reinforced plastic (FRP) and steel
                                                    UST failures, particularly piping failures. Proper
                                                    installation is crucial to ensure the structural integrity
                                                    of both the tank and its piping (which EPA calls the
                                                    "tank system"). Installation includes excavation, tank
                                                    system siting, burial depth, tank system assembly,
                                                    backfilling of the tank system, and surface grading.
                                                    Many mistakes can be made during installation. For
                                                    example, mishandling of the tank during installation
                                                    can cause structural failure of FRP tanks or damage
                                                    to steel tank coatings and cathodic protection. Im-
                                                    proper anchoring, backfilling, inadequate cover, and
                                                    insufficient tightening of loose fittings can also lead to
                                                    system failures.

                                                    Installation problems result from careless installation
                                                    practices that do not follow recognized industry codes
                                                    and procedures. If owners and operators would follow
                                                    the correct installation procedures called for by indus-
                                                    try codes, the number of installation mistakes would
                                                    be significantly reduced. Some of these industry-
                                                    recommended codes are provided by the Petroleum
                                                    Equipment Institute (PEI RP100-86); the National Fire
                                                    Protection Association (NFPA 30); the American
                                                                                               15

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Petroleum Institute (AP11615); and, for installation
of cathodic protection, the National Association of
Corrosion Engineers (RP-01-69 and RP-02-85).

Installation is discussed in more detail in the Preamble
to the proposed regulations (Sections III.B.2 and
VI.B.1) and in the proposed rule (Subpart B,
280.20(c)). In addition, EPA's document on "The
Interim Prohibition" cited above provides an extended
discussion of LIST installation.
Q
       What leak detection methods will
satisfy the leak detection requirements for
new petroleum USTs?
A
       The UST must have a "leak detection
method" that provides monitoring results at least
every 30 days. The leak detection method must be
capable of effectively detecting the stored product.

A leak detection method must be able to detect a
leak in any part of the UST, including the piping.
Leak detection can consist of one or a combination
of the following methods:
                                                     describe several requirements for this combination
                                                     of processes. For example, certain measurements
                                                     must be automatically measured to a 0.125 inch
                                                     accuracy.
Monitoring for Vapors In the Soil

This method samples vapors in the soil surrounding
the UST. Leaked petroleum produces vapors that can
be detected in the soil. The proposed regulations
describe several requirements for the appropriate use
of this leak detection method. For example, use of
this method requires a thorough assessment of the
site, proof that the site is clean, and use of spill and
overfill prevention devices.
Monitoring for Liquids in the Ground Water

This method monitors the ground water near an
UST to determine if petroleum has contaminated
the ground water. Monitoring wells near the UST
are checked frequently to see if petroleum can be
detected.  The proposed regulations describe
several ways to detect petroleum in monitoring
wells. The proposed regulations also describe
several requirements for the use of this method.
For example, this method cannot be used if the
UST is more than 20 feet above ground water.
Tank Tightness Testing and Inventory
Control

This method combines inventory control infor-
mation (measured daily and compiled monthly) with
tank tightness testing conducted twice a year. Tank
tightness testing uses a wide variety of techniques,
which are described in the proposed regulations.
These tests require taking the UST out of service
while either volume changes over time or other
properties are measured.
 Automatic Monitoring of Product Level
 and Inventory Control

 This method combines two automated processes.
 Both processes rely on frequent measurements of
 the tank's contents. The proposed regulations
                                                     Monitoring an Interception Barrier

                                                     Interception barriers are basin-shaped liners partially
                                                     surrounding an UST. Because they are made of
                                                     dense materials that cannot be penetrated by petro-
                                                     leum, these barriers can funnel leaks to the type of
                                                     leak detection methods described above for detec-
                                                     ting vapors and liquids. The barrier does not detect
                                                     leaks, but it can help leak detection methods to
                                                     work more efficiently by directing the leak to a leak
                                                     detector.  The proposed regulations describe
                                                     several requirements restricting the use of this
                                                     method.
16

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Interstitial Monitoring within Secondary
Containment

This method detects leaks in the space between
the UST and a second barrier that more completely
surrounds the UST than the interception barrier
described above.  The proposed regulations
describe several requirements for the application
of interstitial monitoring.
Other Methods Approved by EPA

Many other leak detection methods are being
developed.

A full description of leak detection methods is
presented in the Preamble to the proposed
regulations (Sections III.C.6. and VI.D.) and in the
proposed rule (Subpart B, 280.20; Subpart D,
280.40-41).
                                  LEAK  DETECTION METHODS
                      CONCRETE
         1 -TANK TIGHTNESS  3 - VAPOR MONITORING  5 - INTERCEPTION  BARRIER  7 • OTHER METHODS
            TESTING            IN THE SOIL                                   APPROVED
                                                6 - DOUBLE-WALL  TANK       BY EPA
         2 - IN TANK MONITOR  4 - GROUND-WATER        WITH INTERSTITIAL
                              MONITORING WELL      MONITOR
                                                                                                17

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How Can You Get More Information?
You can call the Hotline (800-424-9346) or contact one of the LIST Regional Coordinators listed below.

EPA Regional UST Coordinators
William Torrey
U.S. EPA, Region I
Kennedy Bldg., Room 1903
Boston, MA 02203
617-223-1595

Tom Taccone
U.S. EPA, Region II
26 Federal Plaza, Rm. 906
New York, NY  10278
212-264-1829

Wayne Naylor
U.S. EPA, Region III
841 Chestnut Street
Mail Code 3HW34
Philadelphia, PA 19107
215-597-7354
Mike Williams
U.S. EPA, Region IV
345 Courtland St., N.E.
Atlanta, GA 30308
404-347-3866

Gerald Phillips
U.S. EPA, Region V
230 South Dearborn St.
Chicago, IL  60604
312-886-6159

William Rhea (6H-A)
U.S. EPA, Region VI
1445 Ross Avenue
Dallas,  TX 75202-2733
214-655-6757
Chet Mclaughlin
U.S. EPA, Region VII
726 Minnesota Avenue
Kansas City, KS 66101
913-236-2852

Henry Schroeder
U.S. EPA, Region VIII
999 18th St., Suite 500
Denver, CO 80202
303-293-1676
Eric Yunker
U.S. EPA, Region IX
215 Fremont Street
San Francisco, CA 94105
415-974-8160

Joan Cabreza
U.S. EPA, Region X
1200 6th Avenue
Mail Stop 530
Seattle, WA98101
206-442-0344
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                                                               V/U.S. GOVERNMENT PRINTING OFFICE: 1987 - 716-002 - 1302/60632

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T^.S. Environmental ?
Eegion 5, Library ;
2&0  S. Dearborn St.-.;
0|ioago,  IL   60604
  \v.,._ .

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OUST
OFFICE OF UNDERGROUND STORAGE T>NKS
Publication Number 26A

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