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EPA addresses underground storage tanks

By Erin Voegele | November 17, 2010
Posted Nov. 23, 2010

The U.S. EPA has released draft guidance on the storage of ethanol- and biodiesel-blended fuels in underground storage tanks (USTs). While the guidance applies primarily to the owners and operators of USTs, members of the biodiesel industry have the opportunity to provide input to the agency via public comments. These comments are being accepted by the EPA through Dec. 17.

While the draft guidance issued by the EPA would apply to USTs delivering gasoline containing more than 10 percent ethanol, no specific percentage threshold has yet been identified by the agency for biodiesel. According to the agency, it is aware that there may be compatibility issues with UST system equipment used to store biodiesel, but does not have any sufficient data on the compatibility of various biodiesel blends with UST system equipment that is currently in use. In other words, much of the research that has been carried out on this type of equipment for ethanol fuel blends has not addressed biodiesel fuel blends. For example, the agency notes that the U.S. DOE is currently testing the compatibility of UST systems with midlevel blends, but to the EPA's knowledge no equivalent testing is being conducted for biodiesel-blended fuels.

The EPA also states that it acknowledges that no UST equipment has been listed by Underwriter Laboratories for use with biodiesel, but also notes that UL has issued a statement indicating that biodiesel blends of up to 5 percent will not require UL investigation. However, the UL statement cited by EPA also said that fuel blends containing higher percentages of biodiesel may have significant impacts on UST materials and components. For these reasons, the EPA said it will be seeking comments on what percentage of biodiesel in fuel blends should be included in the proposed guidance.

Although the EPA is seeking specific comments in several areas, there is one component of the draft guidance that may be of specific interest to those in the biodiesel industry. Regarding the applicability of biodiesel blends, EPA notes that determining an applicable percentage threshold in the absence of compatibility data may lead to rulemaking that is either unnecessarily stringent, or not sufficiently protective. This is because that lack of relevant data makes it difficult to determine whether UST system materials and equipment are compromised by storing biodiesel blends and at what blend percentages these problems are likely to occur. The agency is seeking public input in this area; specifically asking for comments on whether biodiesel-blended fuels should even be addressed by the draft guidance. If the fuel is included, the agency would also like comments to address what percentage should be used. Those providing comments on this topic are asked to provide statistical data in support of their opinion.

There are several other areas in which the EPA is seeking public comment. These include:

- The UST components that might be affected by biofuels. The EPA's proposal currently lists tank or internal tank lining; piping; pipe adhesives and glues; line leak detectors; flexible connectors; fill pipe; spill and overfill prevention equipment; submersible turbine pump and components; fitting, gaskets, brushing, couplings and boots; containment sumps; release detection floats; sensors and probes in this category. The agency is seeking input on whether any of these components should be removed from the list, or if any additional components should be added.

- Methods that can be used to demonstrate compatibility. In addition to UL certification, the EPA is proposing that manufacturer approval could fill this requirement. The agency also notes that it is considering providing flexibility for states that would like to take a different approach. Commenters are asked to provide input on whether these compliance options are appropriate and feasible.

- The criteria for equipment manufacturer approval as a compatibility method. The EPA said it is considering allowing product warrantees, brochures or letters to be acceptable for this purpose. However, the agency specifically notes that the approval should be provided in writing, indicate affirmative statements of compatibility, and be provided directly by the manufacturer, not the equipment installer or distributor. The agency is seeking input on the feasibility of this method, and whether or not other tools might assist UST owners and operator in obtaining this information.

- The ability for UST owners and operators to demonstrate compatibility by these methods. The agency notes that UST systems have relatively long expected lifetimes, and that high turnover rates of owners and operators may make it difficult to locate all relevant documentation on UST equipment. UST owners and operators are asked to comment on their ability to demonstrate compatibility under the proposed criteria.

A full copy of the EPA's proposed guidance can be accessed in the Federal Register.
 

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