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

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? • 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

Yesterday’s Corrosion (Dad’s corrosion)

83%

How bad can it be?

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 •

Corrosion Studies • The role of sulfur • The role of water • Not just a diesel problem • Maintenance more important than ever

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

Microbial Induced Corrosion (MIC) WATER The only known common element in MIC Maintenance can only partially control water accumulation

Microbial Induced Corrosion (MIC)

Fix it like Dad did? • Cathodic Protection • Galvanic protection – sacrificial anode • Impressed current • Liners and bladders

Crank up the Cathodic Protection? • Sea Water 0.15 Amps / Meter 2 • Acid 500 Amps / Meter 2

Keeping Acid from Metal

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

How did we get here? A historical review

1985 UST Regulations Article 6 – UST Repairs H&SC 25296 Special Inspector – California Licensed Engineer UST Repair – Only discussed lining as a repair method.

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

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

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

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

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”

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 or corrosion during the operational life of the underground storage tank system.

Local Agent Authority Article 6 – UST Repairs and Upgrades

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)

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”

Local Agent Authority Article 6 – UST Repairs and Upgrades

Local Agent Authority Article 6 – UST Repairs and Upgrades

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

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

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!

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

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

Bladders • Not prohibited, however… • There are problems associate with installation of bladders in DW systems • Regulations allow in 1998 upgrades only

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?

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

The Repair and Lining Process

The Repair and Lining Process

The Repair and Lining Process

Structural Review • Local agency must review the structural documents • But they look like jabberwocky • Lets review a structural report.

Tank Section Thickness (UL 58) Tank Capacity Original Steel Minimum UL 75% Limit (inches) (US Gallons) Thickness (inches) thickness (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

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.

Where to From Here? • New requested documents by the State Water Board • Proposed regulation changes to Article 6

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

Data Collection

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

Data Collection

Proposed Regulation Changes • Article 6 is changing to Article 10 • Lining inspection will be part of Testing/Inspection article • Requires notification

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

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