Is This Still a Lining? Does it Fit in My Regulations?neiwpcc.org/tanks2015old/tanks2015presentations/2-Monday/Is This... · Is This Still a Lining? Does it Fit in My Regulations?

14SEP15 25th National Tanks Conference & Expo

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Is This Still a Lining?

Does it Fit in My Regulations?

Michael Juranty, P.E.

NH DES

The “New Tank” Perspective

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Our Intent

Lining (Interior Coating): Prohibit as

means of tank repair but otherwise allow

Manway Installation in Host Tank (for

Lining or Repair): Allow [w/ Plan Review]

Co-Structural Double Wall Upgrade: Early

Pilot, now Prohibit

Self-Structural Double Wall Upgrade:

Allow only as a New Field Fabricated Tank

14SEP15 25th National Tanks Conference & Expo 2

Lining or Upgrade vs. New

“Field Fabricated” Tank

Lining = Continued Service of host tank

Upgrade = Continued Service of host tank

Field Fabricated Tank REPLACES host

tank which is Permanently Closed in place


Why Line or Upgrade?

Corrosion Protection of Interior

Failed single walled tank: permanent

closure required

Failed double wall interior: Repair and

tightness test, then may line if wish

Failed double wall exterior: permanent

closure - CANDITATE FOR HOSTING A

FIELD FABRICATED TANK

14SEP15

NTC2015 25th National Tanks

Conference & Expo 4

Lining Considerations

Why is tank being lined?

Repair per rule requirements

Is there existing tank access?


Manway Installations

Many existing steel tanks have no

manways

Hole must be cut for tank repair and/or

lining and upgrades

What is left behind?


Access for Repair and/or Lining


Plan Review –

Manway Installation

API Standard 1631, Interior and Periodic

Inspection of Underground Storage Tanks

UL 58

UL 1746

Manufacturer’s requirement (fiberglass)

NLPA Standard 631, Interior Inspection,

Repair, and Lining of Steel and Fiberglass

Storage Tanks


Manway Install – UL 58


Corrosion Protection – UL 1746


Field Fabricated Tanks

Typically used if host tank experienced an

outer wall failure

Typically cost effective if replacing one

tank within a tank farm

Replaces the Host tank which is closed in

place


14SEP15

25th National Tanks Conference & Expo

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Co-Structural DW Upgrade:

Early Pilot


Xerxes “Phoenix LifeLiner System”

ULC C58.4 “Double Containment Fibre

Reinforced Plastic Linings for Flammable and

Combustible Liquid Storage Tanks”

NH Experience – Waiver Required

Dover UST Facility #0115348, 31MAR10,

Fiberglass Host Tank, 10,000 gallon Diesel

Denied application in a composite tank due to

cathodic protection issues

Co-Structural in Fiberglass Host


Co-Structural in Fiberglass Host


Self-Structural DW Upgrade:

New Tank

TankTech “Stand Alone System”

UL 1316 “Standard for Glass-Fiber-

Reinforced Plastic Underground Storage

Tanks…”

NH Experience: Plan Review Required

Tank Top details (new or used?)

Manchester UST Facility #0111024, OCT13

Salem UST Facility #0111008, OCT13


Host Tank Closure in Place

Had to revise rules to add “tank to host

field fabricated tank” to existing removal

exclusion of “would affect integrity of

structures” for allowing closure in place

Had to revise rules to eliminate “tank

closed in place must be filled with inert

material” requirement if being used as host


Host Tank Permanent Closure

Requirements

Site Assessment

Closure Report

14SEP15

25th National Tanks Conference & Expo 18

Historic Field Fabricated UST

Listings ULC C58.4 “Double Containment Linings”

Xerxes Phoenix

UL 1316 retrofit listing

UL 1316 listing

TankTech Stand Alone Tank System

Containment Solution ReTank system

Now UL 1856

Is a noted listing required to meet 280.20?



Revised Rule: Tank Standards

40 CFR 280.20 “Each tank must be properly

designed and constructed, in accordance with a

code of practice developed by a nationally

recognized association or independent testing

laboratory as specified below:”

(a)(1) tank is constructed of fiberglass-

reinforced plastic; or

(a)(2) tank is constructed of steel and

cathodically protected

Does this include UL 1856?

Note to paragraph (a)(1)

The following codes of practice may be

used to comply with paragraph (a)(1) of this

section: (A) Underwriters Laboratories

Standard 1316, ‘‘Glass-Fiber-Reinforced

Plastic Underground Storage Tanks for

Petroleum Products, Alcohols, and Alcohol-

Gasoline Mixtures’’; or (B) Underwriter’s

Laboratories of Canada S615, ‘‘Standard for

Reinforced Plastic Underground Tanks for

Flammable and Combustible Liquids’’.

14SEP15


Conference & Expo 21


Summary

Develop a reasonable and defensible vision

of what you wish to allow or disallow in

partnership with stakeholders

Gain support and revise rules as necessary

to implement vision and gain program

approval

Scooby Doo Summary

Understand niche of linings/upgrades

Pay attention to mayway installations

Have a plan review requirement

14SEP15


Conference & Expo 23

Contact Information

Mike Juranty

NH DES

[email protected]

(603) 271-6058


mailto:[email protected]

Documents

Is This Still a Lining? Does it Fit in My Regulations?neiwpcc.org/tanks2015old/tanks2015presentations/2-Monday/Is This... · Is This Still a Lining? Does it Fit in My Regulations?