Hi I'm Ryan Haerer with E.P.A.'s release prevention division in the office of underground storage tanks. Thanks for joining the emerging fuels and UST systems compatibility corrosion and degradation session. We will be doing this virtually I recorded this in July so you're actually going to be seeing this sometime in August so sorry we can't be together but what a great opportunity to try something new and do this digitally. So this session we're going to talk about 3 things 1st compatibility requirements for storing biofuels and underground storage tank systems and we're going to talk a little bit about corrosion problems of equipment in UST systems some of the things that you want to be on the lookout for in your UST system and we're also going to talk about a couple new tools that are either out already or maybe coming soon that might help address some of these problems. So let's start here. Are these compatible? Of course not, compatibility is when two things work together, these plugs don't. In the UST world, what we're talking about is that some fuels don't work with some UST systems. EPA has a couple different regulations that focus on different areas. since 1988 when the UST regulation went into effect we've had requirements for external corrosion protection that is required to protect metal pieces from corrosion when it's in contact with the ground. Compatibility is a little little bit different. That's about protecting the inside of UST systems. We've had that requirement since 1988 but then in 2015 when we updated the regulation we added a couple new requirements and we're going to talk through those make sure we get a good understanding. So here are a couple examples of what happens when equipment is incompatible with the fuel that's in the system. These are some pretty bad examples and obviously none of us want anything like this happening to our equipment. Obviously will have a replacement cost to get new equipment but will probably also have a loss of some product to the environment. We don't want that to happen. EPA regulations, as we just said, require compatibility with the substance stored, all the way back in 1988. That's the kind of the green circle, we kept that requirement in 2015. But in this blue circle we have some new rules to help make sure when we store biofuels that they are done safely. When we're talking about biofuels in this context we're talking about only a certain portion of the fields at your store. Most people don't have to worry about these. But if you want to store fuels that have more than 10 percent ethanol like E15 or E85 or biodiesel, more than 20 percent biodiesel, you'll have to follow these regulations and we've got these regulations based on a lot of the things that we learned over the last 30 years. When new fuels would come out they would sometimes degrade some of the equipment so this is based on, this regulation change is based on just a lot of lessons learned the hard way, out in the field. So in detail, these 3 new requirements, if you do want to store biofuels. The 1st is to notify implementing agency 30 days prior to switching your system over to store that fuel, before you go to store E15 or to store E85 for example. We want to make sure that you have the right equipment in place to store that fuel. Then the 2nd part kind of how we do that is that owners and operators must either demonstrate that their system is compatible with the fuel stored or figure out some other option with the implementing agency and then you have to keep records of that compatibility. So let's take an example here. This is unleaded 88 it's a new name for E15 fuel, you might see that around. We'd likely see a lot of stations wanting to store this fuel but if an owner wants to store unleaded 88 or E15 on their system they'll have to follow these additional compatibility requirements, that's because it has more than 10 percent ethanol even though it looks similar to the the other fuel here on this pump. So when we're talking about demonstrating compatibility that number 2 on the requirement, you have to remember that the whole system must always be compatible you know there's you know dozens of components to a UST system. But to demonstrate compatibility you have to do it for more than tanks and the piping. It's the containment sumps, pumping equipment, release detection equipment, spill equipment, overfill equipment, basically any component that's in contact with that fuel we need to make sure it doesn't degrade or fall apart, we need it to work properly to make sure that we can prevent releases of fuels to the environment. So remember everything has to be compatible. We have to show compatibility for those components on the list. So how can you show compatibility? There's 2 ways: the 1st is to show that those pieces of equipment are certified or listed by an independent national laboratory such as Underwriter's Laboratory, UL, that approves its use with the fuel stored; a 2nd option is to demonstrate compatibility through a written approval from the manufacturer of the equipment and that approval has to affirmatively state that it that the components compatible with that fuel you want to store say E15 and they have to say what range fuels it is compatible with. So to meet these demonstrations of compatibility requirements, it kind of takes 2 steps: the 1st is to determine the manufacture and model number of the equipment for the component. You have to know what actual model number and year is installed in the ground at your location, then after we have that information you can determine the compatibility status of that model number component and that's where with that model number we can look for the National Laboratory certification or the manufacturer's statement of approval. So here's a couple examples and the slide I just showed moments ago was a, this is a checklist that EPA published a couple years ago that can help you track those pieces of equipment and how you did demonstrate compatibility. You don't have to use this checklist, but this one and maybe a new one that we have coming out soon will meet those requirements if you want to follow that record. So we just talked through the requirements about this manufacture letters. It has to be an affirmative statement of compatibility, it has to be from the manufacturer, it can't be from your friend or the guy who installed your system. It has to state the range of blends with which is compatible. So let's look here in red: my friend Larry says that I can probably use this widget in my gas tank where we store ethanol fuel. I don't think it meets any of those requirements. But this next page, we see a better option this widget is compatible with and approved to be used with any gasoline-ethanol blend containing 0 to 55% ethanol. It needs to have regulatory requirements, it would cover E15, but it wouldn't cover the E85 because that letter said it only goes to 55 percent ethanol, so that's a little in the details but that's a really important detail and the reason we require that you state the range of the blends is because some blends of ethanol blended gasoline fuels or biodiesel fuels, they don't interact exactly the same. All those components can react a little bit differently, so sometimes 85 percent ethanol might not work when 15 percent ethanol will and vice versa. So where can you find some of these manufacturer letters? Three good sources here PEI, which is the Petroleum Equipment Institute, they've put together an UST component compatibility library. They have a lot of letters there from a lot of their member companies. The California Waterboards, the regulatory agency in California has some good documentation on their website because they have some really strict requirements and fortunately everybody in the country can use you know those resources because they're public. ASTSWMO, the organization the State & Territorial Solid Waste Management Officials, you guys are familiar with them, they have some tools that they have put out to help that find any factual letters as well. So let's talk through National Laboratory listing, remember we could use a manufacturer letter or we could use a national laboratory listing. So here we're going to look at this widget. And we find a little bit of a problem here and this is based on real examples that we have seen a lot in the couple years since the 2015 regulation went into effect. The National listings for Underwriters Laboratories don't always speak to whether or not the component can be used for biofuels so you can find an example of where you can find many many components that have UL listings but it only works for the purposes of meeting the compatibility requirements if that UL listing is specifically testing that component to use biofuels. If it doesn't do that then that's not what we're looking for. So here is a couple things to remember: we want the UL listing to match the install component, that's the 1st thing, it has to match what you have in the ground if you want to use it; then we have to make sure that that standard is approved for that. Over the last couple of years EPA worked with Underwriters Laboratory, the main independent testing lab, after our rule came out and we helped them develop a tool that can help assist owners and operators identify the appropriate listings for the equipment and their UST system. It can be a little bit, it used to be a little bit confusing but now with this tool it's much better, but always reach out you're implementing agency and you know there will be some assistance if when you want to demonstrate compatibility and check your components you can always get help for that process the important thing is you have that communication and dialogue. So pipe dope and sealants, they're not on the list of components required to be demonstrated compatible but they are required to be compatible with the substance stored. Remember that all components of the UST system, since 1988, must always be compatible so this is especially important remember as you look to store biofuels because the sealants come in both compatible with ethanol and higher diesel blends and incompatible options. EPA has some questions and answers posted on this on our website. It can be a little bit confusing but probably if you had an older system in the ground you probably have some incompatible connections because compatible versions of this didn't even come out till around 2007 and likely if you installed your station since 2007 you still might have had an incompatible version used if you didn't specifically intend to store biofuels and therefore asked for this version to be used on your system. So here's an example in the red, of some locations where pipe dope might be used on a UST system so if you're inspecting you're not going to be able to see all these but you will know, you have to consider the age of the UST system and if any repairs are made. Whether or not they would be able to have compatible pipe dope at these locations. So after you go through this process you check for each of those components on that list the tank, the piping, the containment sump, etc. You might find that you, you know, can't determine compatibility for all the components on that list or maybe don't have pipe dope and sealants, etc. When you find that you can demonstrate compatibility there you have a couple options: the 1st is you could do targeted retrofits to replace that equipment that didn't have, you know, compatible equipment or you can prove that it was compatible. That's probably going to happen with more sort of more recent systems that are already have, where you find that the tank and the piping are compatible you might be able to change out the ancillary equipment or some of those sumps, etc. You can also install a new system in the ground and if you install something new or or if you're making a repair or retrofit you always want to make sure that if the intent is that you want to store biofuels, that you ask for the versions of the equipment that are high biofuels compatible. Installing new system you know is very expensive but that is an option. The 3rd option, if you can't demonstrate compatibility is to choose not to store the substance, that is always an option, you know most stations in the country don't store biofuels, so that would be the 3rd option, is not to store the higher blends of biofuels if you can't determine your system's compatible. This is an external resource that you might find helpful, this came out in 2019. We worked with the Fuels Institute on this document and this is a good document I think because while we have really specific documents to EPA regulations this document looks at EPA regulations to sell biofuels at you know from the US you know from a gas station. It includes our UST requirements but it also includes other requirements that you may have to follow so this is free and accessible on the Internet retailing biofuels, we recommend you check that out prior to deciding if you want to store biofuels, that help give you a sense what you might need to do. So for the UST compatibility section, before we move to corrosion you know let's wrap up- 3 key points: everything in your UST system must be compatible with whatever fuel you store. If you store over 10 percent ethanol or more than 20 percent biodiesel then you have to notify the agency demonstrating compatibility of your components and then make sure it's not just the tank and piping and then you have to keep records of that information for as long as you store that fuel. The 3rd is that most existing systems are likely not compatible for these without changes, unless you specifically requested compatible components you would probably need to make some changes. So let's move on to corrosion. So 1st we're going to talk about corrosion, but we're also going to talk about using the word degradation. Corrosion we also often think of it happening to, more to metal so we're largely we can use that word degradation. Sometimes fuels degrade equipment, that can happen for compatibility but it can also kinda happen from this other process so so for here we're going to use a word corrosion but know that it might, degradation could sometimes be a better word for what can happen to your UST systems. So these pictures are gasoline and ethanol blends and many of you have probably seen pictures similar to this. We see this type of corrosion, it's everywhere in gasoline and ethanol blends including E10, it's not just if you're storing biofuels, this happens anybody you know almost every station in the country could be susceptible to this type of an issue. Sometimes we hear of releases but primarily we hear of it being a servicing concern to the equipment, eventually components could rust away and fail. So here you go, here are a couple pictures a failing equipment, sometimes you smell vinegar when you lift up the sump lid, that's acetic acid, which is responsible for this corrosion. You often see bright blue corrosion on the copper tube, here in this picture you can see some corrosion of the, you know the riser pipe there and then you can see one completely broken off in the right side picture. So whenever you do a UST inspection or you're looking at your equipment you always, you know, when you lift up the sump lids, be aware of that corrosion that's going on so it's pretty common but they do have some new treatments that are out there that may help you prolong the life of your equipment or maybe minimize the corrosion that you might see down the gas line. But unlike gasoline, diesel has corrosion too but it's a little bit harder to see, it's primarily inside of diesel systems where you can't see it. You know you might be able to see some if you look down inside the drop tubes that's what this picture is, EPA did some research a couple years ago and this this is a picture from the camera that was pretty striking, that that's a lot of corrosion. Sometimes this can keep your leak detection equipment etc from working if you can't get it in or out or the overfill valve might stop working. We'll see some pictures of that in just a second. How widespread is this problem? Well nobody knows for sure, but EPA did some research in 2016 and what we were looking for this problem we asked people before we came out of their sites if they had this issue. 83 percent of the USTs had moderate or severe corrosion, that's how we rated that and the problem was that most people even though they said "you know come out and look at our system" you know less than 25 percent thought they had a problem before you got there so the fact that 83 percent had you know had decent level problems that was pretty striking. We did find that it affected one region of the country more than the other out of the cities that we looked at. From what we hear continue to hear anecdotes that this could be pretty widespread and the problem is if you're not really looking for it you generally won't hear of it until you have a little bit of an issue, maybe your filter slows down in your diesel system or some equipment breaks. So here's where the diesel corrosion matters you mention that a 2nd ago but it can affect any metal equipment inside of a UST system, so it definitely will increase servicing costs you might have to replace equipment earlier, you might have to change your filters more often because you kind of get the coffee grounds from the equipment degrading that flows into the fuel and then blocks up your filter. But release prevention equipment could fail we have some evidence or you know we hear some anecdotes I should say of overfill prevention equipment that doesn't work in diesel systems, all float valves rust out, they don't work. Here you know shear valves or fire valves, crash valves whatever you want to call them at the surface level that jam up and don't work, also hear about the line leak detectors, mechanical line leak detectors jamming up not work so these are pros and presents real problems. We're also worried about the tank integrity. Primarily we were worried about this in steel tanks obviously because that's a metal surface that can corrode, there's always been a slight chance of corroding out the bottom of a steel tank that store diesel fuel, but generally it was a small risk and it was you know not too much of a problem if the water in the bottom was manageable but now we hear that there might be a little bit more of a risk with these bad corrosion problems that we've seen that started around 2007. There's also some anecdotes that we're hearing about fiberglass tanks that are storing diesel fuel that don't really get the metal corrosion you know they get it on the metal components but starting to worry about or wonder if that might be happening a little bit to some of the the bottoms of fiberglass tanks too, softening a little bit so we don't have any real evidence of that but please let us know are definitely looking into some of these anecdotes that we're hearing. This corrosion issue, we did a nationwide notice to owners after this, after we found this corrosion problem and diesel fuels you can find that here but it kind of discusses what the problem is, the background, and some some steps you can take proactively to try to minimize the risk of having this problem. Remember it's out of sight out of mind often and so you have to be active with these systems to make sure you don't have a problem. So ASTSMWO, they created some other good tools besides the Manufacturer Letter Library, they also have a degradation reporting tool. This is to help track these corrosion and degradation related failures and problems across the country so owners can go in and submit information here voluntarily, you don't have to give the information about your site or who you are. But this will be helpful to help understand this program. Issue nationwide because EPA generally doesn't have this type of information available. So we hear anecdotes, but we don't have real evidence and we certainly don't have wide numbers of information collected on this issue. So here you can see these are the states that have submitted information, this is the screenshot from last year so you know it probably has more information but what we want to do is fill up every state in the country here, giving some examples of these corrosion problems that they're seeing. This is going to help us, you know ASTSMWO will figure out, you know maybe are there some trends here that we can figure out, what is happening in certain areas, is it the weather or is it the fuel supply that they are getting. We want to use that information to help share, you know, work with people to share that information and also work on solutions to see how how we can minimize this for our UST owners and operators. Nobody wants this problem and we we don't want, we certainly don't want releases because of this problem. So just remember in the emerging fuels world and we're talking about compatibility and corrosion and new fuels coming out, doing new things to the infrastructure, that everything is fluid. So a couple questions, that concludes the presentation, but after this, later on there will be a birds of a feather session and we have a couple questions here we want you to think about. We closed with corrosion, we'll start with that on the questions what type of corrosion problems are you experiencing in your gasoline systems and in your diesel systems. Are you seeing these problems, you know, and if so what kind of equipment was affected? You know how are you dealing with that? Are you being preventative are you finding problems and replacing any equipment after? A lot of things to discuss there. The 2nd question goes to what we talked about 1st. Have you considered storing biofuels like E15 or anything that has more than 10 percent ethanol or 20 percent biodiesel? If so ,what was your experience when you look to determine the compatibility of your UST system or did you even know that you needed to determine compatibility of your UST system? The new requirement, 5 years ago, so it could be that maybe we didn't do a good enough job communicating the information. Whatever, we want to know, we would like to hear what everybody's working on and this is an opportunity for all of us to learn from each other. So come with some good questions I look forward to asking you guys a lot if I can make it and I hope that we can all learn quite a bit from this. So if you have any questions here's my contact information please feel free to reach out anytime. Oops, I forgot to change the slide. I'm with the release prevention division at EPS and happy to talk compatibility corrosion or anything like that at any time, thank you very much.
Emerging Fuels and UST Systems: Compatibility, Corrosion, and Degradation
From ITEP Team July 15th, 2020
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