Is This Still a Lining? Does it Fit in My Regulations?

Transcription

1 Is This Still a Lining? Does it Fit in My Regulations? The New Tank Perspective Michael Juranty, P.E. NH DES 14SEP15 25 th National Tanks Conference & Expo 1

2 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 25 th National Tanks Conference & Expo 2

3 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 14SEP15 25th National Tanks Conference & Expo 3

4 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 NTC th National Tanks Conference & Expo 4

5 Lining Considerations Why is tank being lined? Repair per rule requirements Is there existing tank access? 14SEP15 25 th National Tanks Conference & Expo 5

6 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? 14SEP15 25th National Tanks Conference & Expo 6

7 Access for Repair and/or Lining 14SEP15 25th National Tanks Conference & Expo 7

8 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 14SEP15 25 th National Tanks Conference & Expo 8

9 Manway Install UL 58 14SEP15 25th National Tanks Conference & Expo 9

10 Corrosion Protection UL SEP15 25th National Tanks Conference & Expo 10

11 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 25 th National Tanks Conference & Expo 11

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13 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 # , 31MAR10, Fiberglass Host Tank, 10,000 gallon Diesel Denied application in a composite tank due to cathodic protection issues 14SEP15 25 th National Tanks Conference & Expo 13

14 Co-Structural in Fiberglass Host 14SEP15 25th National Tanks Conference & Expo 14

15 Co-Structural in Fiberglass Host 14SEP15 25th National Tanks Conference & Expo 15

16 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 # , OCT13 Salem UST Facility # , OCT13 14SEP15 25 th National Tanks Conference & Expo 16

17 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 14SEP15 25th National Tanks Conference & Expo 17

18 Host Tank Permanent Closure Requirements Site Assessment Closure Report 14SEP15 25 th National Tanks Conference & Expo 18

19 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 ? 14SEP15 25 th National Tanks Conference & Expo 19

20 Revised Rule: Tank Standards 40 CFR 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 fiberglassreinforced plastic; or (a)(2) tank is constructed of steel and cathodically protected Does this include UL 1856? 14SEP15 25 th National Tanks Conference & Expo 20

21 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 NTC th National Tanks Conference & Expo 21

22 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 14SEP15 25 th National Tanks Conference & Expo 22

23 Scooby Doo Summary Understand niche of linings/upgrades Pay attention to mayway installations Have a plan review requirement 14SEP15 NTC th National Tanks Conference & Expo 23

24 Contact Information Mike Juranty NH DES (603) SEP15 25 th National Tanks Conference & Expo 24