Repair and Lining in the 21 st Century What we talk about when we - - PowerPoint PPT Presentation

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Repair and Lining in the 21 st Century What we talk about when we - - PowerPoint PPT Presentation

Sep 17, 2023 666 likes •1.2k views

Repair and Lining in the 21 st Century What we talk about when we talk about lining CUPA Conference 2018 Tom Henderson Engineering Geologist State Water Resources Control Board UST Leak Prevention Unit February 2018 Why Should You Care?

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Tom Henderson Engineering Geologist State Water Resources Control Board UST Leak Prevention Unit

Repair and Lining in the 21st Century

What we talk about when we talk about lining CUPA Conference 2018

February 2018

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Why Should You Care?

  • Corrosion today – This ain’t your father’s corrosion
  • History of regulations for repairs and lining
  • Your part in repairs and upgrades
  • Where are we going with regulations
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Yesterday’s Corrosion

(Dad’s corrosion)

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83%

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How bad can it be?

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US EPA 2016 Report on UST Corrosion

  • Owners likely unaware of problem
  • 83% of diesel UST with moderate to severe corrosion
  • Very limited sample size
  • Geographically widespread
  • Ethanol present in 90% of ULSD systems
  • Water and particulate content most likely predictors
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Corrosion Studies

  • The role of sulfur
  • The role of water
  • Not just a diesel problem
  • Maintenance more important than ever
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Microbial Induced Corrosion (MIC)

ULSD Sulfur - Correlation or causation? No evidence sulfur concentration affects MIC Fuel processing Biofuels and ethanol Gasoline – not just a diesel problem Fiberglass – not just a steel tank problem

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Microbial Induced Corrosion (MIC)

WATER

The only known common element in MIC Maintenance can only partially control water accumulation

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Microbial Induced Corrosion (MIC)

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Fix it like Dad did?

  • Cathodic Protection
  • Galvanic protection – sacrificial anode
  • Impressed current
  • Liners and bladders
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Crank up the Cathodic Protection?

  • Sea Water

0.15 Amps / Meter2

  • Acid

500 Amps / Meter2

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Keeping Acid from Metal

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Water Board Observations

  • Requested Data
  • Data collection not scientific, random or mandatory
  • Request information from CUPAs and Contractors
  • In first five weeks of request, SWRCB received four

notifications for leaking primaries

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How did we get here?

A historical review

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1985 UST Regulations

Article 6 – UST Repairs H&SC 25296 Special Inspector – California Licensed Engineer UST Repair – Only discussed lining as a repair method.

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1985 UST Regulations

Article 6 – UST Repairs

  • All repairs required a special inspector
  • Structural integrity inspection required
  • Lining was part of UST Repair – primary method
  • Upgrade was not used in Article 6
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1991 UST Regulations

Article 6 – UST Repairs and Upgrades Everything changed in preparation for 1998 Upgrades

  • Lining was now a separate section
  • Special inspections became part of lining only
  • No other repair method required the special

inspection - specifically

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Where are we today?

Article 6 – UST Repairs and Upgrades Post 1998 Upgrades UST Repairs include unauthorized release - 2660(b) Local agency instructions – 2660(k) Frankensteinization

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Double walled USTs

Article 6 – UST Repairs and Upgrades “Repair“ means to restore a component that has caused a “release” - CCR “Release” is a loss to the environment – H&SC

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Double walled USTs

Article 6 – UST Repairs and Upgrades UST Repairs include unauthorized release - 2660(b) This is the only place in regulations that call out repairs of “unauthorized release”

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Local Agent Authority

Article 6 – UST Repairs and Upgrades

Title 23, Division 3, Chapter 16, Article 6, Section 2660(k) Local agencies shall not approve a repair or upgrade unless it can be demonstrated that the underground storage tank is structurally sound and the method of repair or upgrade will prevent unauthorized releases due to structural failure

  • r corrosion during the operational life of the underground

storage tank system.

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Local Agent Authority

Article 6 – UST Repairs and Upgrades

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Local Agent Authority

Article 6 – UST Repairs and Upgrades How can I tell if the tank is structurally sound?

Ask the contractor how they are confirming the tank is structurally sound. What methods did they use to determine sound? Internal inspection requirements 2663(b)

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Local Agent Authority

Article 6 – UST Repairs and Upgrades Structurally sound if:

  • 75% of original wall thickness,
  • No open seam or split longer than three inches,
  • No one perforation greater than 1.5” or 2.5” for tank

gauging location,

  • Four or less perforation in a one a square foot, and
  • Multiple perforation with none larger than 0.5”
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Local Agent Authority

Article 6 – UST Repairs and Upgrades

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Local Agent Authority

Article 6 – UST Repairs and Upgrades

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UST Repairs or Upgrade

General requirements

  • Materials applied must be compatible
  • Must be applied in accordance with nationally

recognized engineering practice

  • Records maintain for the life of the tank
  • Must demonstrate the tank is structurally sound
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UST Repair Requirements

  • Must demonstrate the tank is structurally sound
  • Local agency approval required prior to repair
  • Repaired once by lining method
  • Tightness testing
  • Monitoring well if no secondary containment
  • Continuously monitored
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UST Lining Requirements

  • Liners can be upgrade or repair
  • USTs lined as repair may not be lined again as

repair But wait…I have a tank that was repaired and then lined at the same time. NO!

  • 1. Repair first
  • 2. Tank Tightness test after repair
  • 3. Then, line the tank!
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UST Lining Requirements

  • Must demonstrate the tank is structurally sound by

a professional engineer

  • Local agency approval required prior to lining
  • Tightness testing
  • 10/5 year lining inspection
  • Inspection by an engineer or coatings expert
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10/5 Year Lining Inspection

  • Results to local agency within 30 days
  • Notification requirement?
  • Structural integrity?
  • Certification either:
  • Certifies for 5 more years
  • Reline plus 5 more years
  • Condemn
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Bladders

  • Not prohibited, however…
  • There are problems associate with installation of

bladders in DW systems

  • Regulations allow in 1998 upgrades only
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Lining for Compatibility

  • Issues to consider -
  • Integral secondary containment must also be

compatible

  • Some early FRP USTs do not meet this
  • If water in UST bottoms becomes contaminated by

MIC acetic acid, does the liner need be compatible with acetic acid?

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Lining and CERS

  • CERS must be updated to show the new primary

condition

  • “Steel/FRP with liner” as primary containment
  • UST Certification of Installation/Modification

Form

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The Repair and Lining Process

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The Repair and Lining Process

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The Repair and Lining Process

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Structural Review

  • Local agency must review the structural

documents

  • But they look like jabberwocky
  • Lets review a structural report.
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Tank Capacity (US Gallons) Original Steel Thickness (inches) Minimum UL thickness (inches) 75% Limit (inches) <285 0.070 0.067 0.052 286 to 560 0.094 0.093 0.071 561 to 1100 0.125 0.123 0.094 1101 to 4000 0.172 0.167 0.129 4001 to 12000 0.250 0.240 0.188 12001 to 20000 0.312 0.302 0.234 20001 to 50000 0.375 0.365 0.281

Tank Section Thickness (UL 58)

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Structural Review

  • Review your documents before repair/upgrade!
  • What methods used?
  • How many holes, tank condition?
  • Does the repair match the methods?
  • What methods used in manway installation?
  • Challenge the information given you.
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Where to From Here?

  • New requested documents by the State Water

Board

  • Proposed regulation changes to Article 6
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Data Collection

  • The State Water Board has requested notification

from the local agency for any UST entry

  • Entry Notification Form

Includes basic facility information Date of entry Contractor performing work/inspection

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Data Collection

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Data Collection

  • The State Water Board has demanded internal

inspection information from contractors

  • Internal Inspection Form

Includes basic facility information Date of entry Contractor performing work/inspection Reason for UST entry Comments/Observation

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Data Collection

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Proposed Regulation Changes

  • Article 6 is changing to Article 10
  • Lining inspection will be part of Testing/Inspection

article

  • Requires notification
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Proposed Regulation Changes

New Repair/Upgrade Requirements

  • UST certification by a special inspector required

before all repairs or upgrades

  • Change in inspection pass/fail criteria
  • Lining for upgrades only
  • Integrity testing varies based on UST installation

date

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SLIDE 52

Tom Henderson (916) 319-9128 tom.henderson@waterboards.ca.gov

Contact