The Silent Equipment Killer

What ASTSWMO UST Task Force Found

The ASTSWMO UST Task Force solicited information for fiscal year 2012 from all 50 states, five territories, and the District of Columbia in an effort to determine the violations most often encountered during UST compliance inspections. Responses were received from 35 states and territories, covering nearly 59,000 UST inspections and more than 37,000 violations.

A review of the data identified corrosion protection as one of the top five inspection violation issues. According to the report, in reference to corrosion protection, there were 2,811 total violations, 49 percent of which were for failure to perform the 3-year CP test, and 20 percent for failure to maintain and operate the CP system properly. Another 17 percent of the violations were for unprotected metal in contact with soil or water, and 7 percent each for failure to complete the 60-day CP operational test and failure to maintain records.

Some Facts About Corrosion

“Corrosion” can be defined as the degradation of a material because of a reaction with its environment.

According to the a study initiated by NACE International (formerly the  National Association of Corrosion Engineers), which was funded by the U.S. Federal Highway Administration, the annual cost of corrosion is $276 billion and affects every industry sector in the United States. (Note: The study was done in 2002 but is still considered influential in the field).

Corrosive chemicals are most often thought of as being liquids. But they can also be solids, such as granules or powders. Corrosive gases or mists are often released from concentrated corrosive liquids.

Because metals are the most used type of structural materials, such as tanks, we will focus on the corrosion of metals. According to NASA’s Corrosion Technology Laboratory, most corrosion of metals is electrochemical in nature.

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Check for Corrosion in Your AST

Simple AST checks you can perform to prevent corrosion include:

1. Have the tank either elevated with the underside in contact only with tank supports and/or on a concrete pad designed to prevent water accumulation under the tank floor.
2. Make sure the tank is cathodically protected and internally lined according to American Petroleum Institute (API) Standard 652 (Lining of AST Petroleum Storage Tank Bottoms) and internally inspected according to API Standard 653 (Tank Inspection, Repair, Alteration, and Reconstruction).
3. During visual inspections, note the general appearance of paint on the shell, roof, ladder, and structural members.
4. Is rusting or pitting occurring on any of the above?
   If yes, explain where and if repairs are needed immediately.
5. Are all insulating flange washers and sleeves in place?
   If missing, cracked, or broken, explain where and repairs needed.
6. Are all ground and/or anode straps in place?
   If missing or damaged, indicate location on a drawing and explain repairs needed.
7. Make sure that the secondary containment system is free of tank product or other liquids/debris (e.g., rainwater, snowmelt, dirt, leaves, trash, stored materials).
8. Make sure that concrete surfaces and the ground are free from any evidence of spills or leaks.

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Check for Corrosion in Your UST

Under current UST regulations, new tanks must be constructed of coated and cathodically protected steel, fiberglass or reinforced plastic, or steel clad with fiberglass. New piping must be made of coated and cathodically protected steel or of fiberglass. All cathodic protection systems must be tested within 6 months of installation and, after that, at least every 3 years.

Note: The EPA released final amendments to UST regulations in late June. The UST amendments are effective 90 days after publication in the Federal Register.

The final amendments to the UST regulations replace the option of constructing new tanks from a steel-fiberglass-reinforced-composite with the option of constructing the tank of steel that is clad or jacketed with a non-corrodible material.

In addition, under the final amendments to UST regulations, UST owners and operators must permanently close tanks that use internal lining as the sole method of corrosion protection if the internal lining fails the periodic inspection and cannot be repaired according to a code of practice. The 1988 regulations allowed lining as an upgrade option to extend the life of some tanks. While linings extended the life of many tanks, the EPA did not consider this a permanent solution. As the tank linings fail, these older tanks must be taken out of service to prevent releases to the environment. This requirement is effective immediately upon the effective date of the amendments (i.e., 90 days after publication in the Federal Register).