An Underground Solution

U.S. EPA issues guidance on underground storage tanks
By Erin Voegele | August 16, 2011

New resources are now available to those who want to store biofuel-blended fuel in underground storage tanks (USTs). On July 5, the U.S. EPA published guidance on the compatibility of USTs with fuel blends containing more than 20 percent biodiesel or more than 10 percent ethanol.

In a statement provided to Biodiesel Magazine, the EPA outlines the reasoning behind its issuance of the guidance. “Given the increase in use of biofuels, a greater number of [UST] systems will likely store biofuels in the future,” says the agency. “This may also mean a greater number of UST systems could store fuel blends that contain higher percentages of biodiesel.”

According to the EPA, the guidance applies to Indian country and in states that do not have state program approval (SPA). Information provided by the agency states that 36 states, the District of Columbia and Puerto Rico, have SPA. The agency notes that the guidance may also be useful to those living in SPA states because they must have a compatibility requirement that is similar to federal requirements. However, the agency also says it “encourages approved states to develop their own guidance regarding the compatibility of UST systems with biofuel blends.”

Specifically, the guidance discusses how owners and operators of USTs that are regulated under 40 CFR part 280 of the Clean Air Act can demonstrate compliance with the agency’s compatibility requirements for fuels containing more than 20 percent biodiesel or 10 percent ethanol. According to the EPA, federal UST regulation 40 CFR 280.32 has been in existence since 1988.

Regarding the storage of biodiesel fuel in USTs, the EPA says it understands that the vast majority of biodiesel stored in these systems is either B5 or B20. “Available data indicate these blends do not present a significant material compatibility concern,” the agency says. “Therefore, the June 2011 guidance applies to the small number of USTs that are storing greater than 20 percent biodiesel.”

 The underground compatibility requirement regulation states that owners and operators of underground storage systems that supply these fuels must use UST systems made of or lined with materials that are compatible with the biofuel blends. In the guidance, the EPA states that “because the chemical and physical properties of ethanol and biodiesel blends may make them more aggressive to certain UST system material than petroleum, it is important that all UST system components in contact with ethanol or biodiesel blends are materially compatible with that fuel.”

The agency explains that until the mid-1980s most USTs were made of bare steel, which is likely to corrode over time, allowing contents to leak. Faulty installation, inadequate operating and maintenance procedures are also named as possible causes of leaking. According to the EPA, the leaking of USTs can cause soil and groundwater contamination, in addition to other health and environmental risks, including the potential for fire and explosion.

To achieve compliance for newly installed equipment comprised of multiple individual components such as submersible turbine pump assemblies, the agency states that UST owners and operators can obtain certification from the equipment manager that documents the compatibility of the entire assembly. If, however, the equipment requires maintenance and components of the equipment are later added or replaced, manufacturer approval of the overall component is not sufficient.

The EPA outlines three acceptable methods to demonstrate compatibility. First, owners and operators can use components that are certified or listed by a national recognized, independent testing laboratory. Second, they many use components approved by the manufacture as compatible with the fuel being stored. Manufacturer approvals must be in writing, indicate an affirmative statement of compatibility, specify the range of biofuel the component is compatible with and be issued by the manufacturer—not the installer or distributor. Third, owners and operators can use another method determined by the implementing agency. EPA says it will work with states as they evaluate alternative methods that fall into this category.

—Erin Voegele

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