Petrogram - Spring 2010 - (Page 22)
FEATURE E-10 and Single-Wall Fiberglass Tanks… Are There Emerging Problems with Compatibility? Marshall T. Mott-Smith urprises are not often welcome in the world of managing underground storage tank systems. We all prefer the predictability and comfort that time-tested technologies provide. However, when surprises occur with these trusted technologies, it is truly an unsettling situation. “Surprise” is a word that best characterizes recent observations reported by inspectors performing internal inspections of older single-wall fiberglass underground storage tanks (before the mid-1980s) that have been converted S to E-10 service. These inspections and observations have been performed and discovered all around the country, but mostly in Florida. In several parts of the country, E-10 has been in use for over 20 years. However, in the last two years, the transition from MTBE as an oxygenate to 10 percent ethanol (E-10) came to UST owners and retail consumers of unleaded gasoline in the rest of the country with little fanfare. The conventional wisdom and guidance from government regulators, industry experts and associations, testing laboratories and consulting professionals was that E-10 was generally compatible with all of the components of UST systems. The primary operational concerns have been an increase in fuel ﬁlter maintenance and increased vigilance with keeping water out of the bottom of USTs, given the propensity for ethanol to combine with water. At the time of the transition to E-10, most UST systems around the country were compliant with the 1998 Environmental Protection Agency deadline for single-wall corrosion-protected tank systems. Some states like Florida, California and several New England states with rules more stringent than the federal 1988 EPA technical standards, have a higher percentage of underground storage tanks with secondary containment. Many other states have a higher percentage of single-wall corrosion-protected tanks than double-wall tanks. Additionally, after the Energy Act in 2005, most states only require secondary containment for new and replacement tanks and not for existing tanks. Given this situation, there is usually no reason to perform internal inspections on single-wall corrosion-protected tanks except for in those few states requiring existing single-wall tanks to upgrade with secondary containment. The December 31, 2009 Florida Department of Environmental Protection secondary containment deadline for underground tanks was established in 1990. At the end of the 2009, approximately 86 percent of the UST facilities in the state had upgraded their tanks with secondary containment. Of the 10,000 facilities with 23,000 USTs in Florida, over 1,000 USTs have been upgraded with internal methods of ﬁeld-installed secondary containment. Prior to installation of internal secondary containment, an internal evaluation of the integrity of the UST must be performed in accordance with NLPA (National Leak Protection Association) Standard 631. This includes the assessment of the tank wall thickness, internal corrosion, hardness and general internal conditions. Photographs are taken to document the inspector’s ﬁndings. UST’s that fail the NLPA 631 evaluation criteria must be repaired, and if that is not possible, they must be replaced. Field observations Again, in Florida, E-10 has only been marketed by service stations and convenience stores for about two years. In the past two years, it has come to the attention of the inspectors performing these internal secondary containment evaluations that over one half of the singlewww.fpma.org 22 | Petrogram | Spring 2010
Table of Contents for the Digital Edition of Petrogram - Spring 2010
Petrogram - Spring 2010
A Celebration of the Petrogram’s 50th Anniversary
How to Stage a Great Grand Opening
FPMA Efforts to Improve the Cleanup Program
Out & About the Industry
E-10 and Single-Wall Fiberglass Tanks
Are You Ready for PCI Compliance?
Crind and Bear It
Index of Advertisers/Advertiser.com
Petrogram - Spring 2010
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