1. What is cathodic protection?
    
2. Are my underground storage tanks in compliance with EPA regulations?
    
3. Do I have to test my pressurized product lines and how often?
    
4. Do I have to test my line leak detectors and how often?
    

5. Which type of suction line do I have to test, and when?
    

6. If I have cathodic protection on my fuel system how often do I have to test it?
    

7. Does my automatic tank gauge have to be tested each year?
    

8. If my leak detector starts “triping” or goes into alarm do I have a leak?
    

9. Can tanks which are older than 10 years be upgraded with cathodic protection?
    

10. I have double wall fiberglass tanks, do I have to perform  leak monitoring on the tank?
     

11. My tanks are upgraded, do I have to continue to perform tank tightness tests?
     

12. My diesel system is experiencing a bacteria growth problem, what can I do?
     

13. My pipeline has developed a leak do I have to replace the entire pipeline?
     

14. When do I need to start monthly monitoring of my underground storage tanks?

What is cathodic protection?

Cathodic protection is a method of external corrosion prevention for underground fuel storage tanks and their associated piping. It is a recommended method because it protects your investment in underground storage tanks and helps protect you from liability, litigation and cleanup costs associated with fuel leakage. It is technically sound and it is a proven approach to corrosion prevention.

A cathodic protection system applies principles of electrochemistry in providing a current which will counteract the local environment's corrosive current. First Action Systems provides "Tank Environmental Profiling" or TEP® technology testing is used to determine the corrosive state of the tank.

There are two methods of cathodically protecting a tank. One is a passive system that protects the tank by surrounding it with galvanic anodes. The anodes are made of a material more corroding in the electromotive series than the steel of the tank. The other is an impressed current system that utilizes buried anodes made of high silicon, cast iron or graphite. The anodes together with a rectifier are used in order to generate the necessary counter-acting current.

Are my underground storage tanks in compliance with EPA regulations?

Most regulated tanks should comply with three regulations:

1. A leak detection system;
    
2. A spill containment basin;
    
3. Overflow shutoff valves.

More information concerning these requirements can be obtained in an EPA Compliance Manual which is available from our office.

Before making substantial expenditures concerning the above regulations, the fourth regulation, corrosion protection, should be addressed. There are two paths for dealing with this regulation. The first, and most obvious, is to install new tanks equipped with corrosion protection. This option is by far the most expensive and time consuming. To follow this path, not only the expense of the new tanks is involved, but the excavation for installing new tanks, and removal of the old tanks are additional costs. The unknown cost of business interruption must also be considered.

The second path is considerably less expensive. Retrofitting your existing tanks may not involve any of the above expenses. The EPA currently estimates 85% of the tanks being replaced are good tanks which could have been saved through retrofitting.

To make a decision about the correct path to EPA compliance, you need specific information about the condition of existing tanks. In fact, the law requires you to inspect tanks for corrosion holes prior to retrofitting. While more costly methods exist, most states have accepted the EPA's recent compliance recommendation for a noninvasive means of inspecting tanks.

Tank Environmental Profile (TEP®) is a cost effective, non-invasive method of inspecting tanks. TEP® meets and exceeds the EPA's recommended guidelines in ASTM Standard G-158. TEP® will provide you with the information necessary to choose your path to compliance. TEP® will satisfy the legal requirements for inspection and tank test information. This new procedure should be completed before any additional deterioration takes place.

Do I have to test my pressurized product lines? How often?

According to Federal Regulation 40 CFR 280.41 (b)(ii) all pressurized piping must be tested for leaks on a yearly basis unless there is a automatic leak monitoring system which performs monthly monitoring on the piping.

Do I have to test my line leak detectors? How often?

Federal Regulation 40 CFR 280.44 (a) requires that all product line leak detection equipment (mechanical or electronic) are tested on a yearly basis for the 3.0 gallon per hour leak detection threshold.

Which type of suction line do I have to test, and when?

Only un-safe suction lines (those with a check valve in the base of the suction line) require testing.  This testing must be performed on a three year schedule.  See Federal Regulation 40 CFR 280.41 (b)(2).

If I have cathodic protection on my fuel system how often do I have to test it?

Federal Regulation 40 CFR 280.31 (b)(1) requires all corrosion protection systems to be tested within 6 months of installation and at least every 3 years thereafter.

Does my automatic tank gauge have to be tested each year?

Federal Regulation 40 CFR 280.40 (2) requires that all electronic monitoring equipment installed on petroleum systems be maintained in accordance with the manufacturer's instructions (annually).  This includes tank gauges, automatic line leak detection, over-fill alarms, and any liquid or vapor (both wet and dry) sensors.

If my leak detector starts “tripping” or goes into alarm do I have a leak?

There are numerous instances when a leak detector will indicate a leak without actually having a leaking system.  Qualified service personnel should verify the correct operation of the leak detection system, including check valves, water in sumps, and also perform a tightness test of the line to verify that there is not a leak.  Many times simply replacing a leaking "o" ring or a faulty check valve is all that is needed to put the fueling system back into full service.

Can tanks which are older than 10 years be upgraded with cathodic protection?

Yes. Tanks must be inspected for tightness prior to installation of the cathodic protection system.  In addition, an internal inspection of the tank or a Tank Environmental Profile must be performed to determine the fitness of the tank prior to installation of the cathodic protection system.

I have double walled fiberglass tanks, do I have to perform  leak monitoring on the tank?

Yes.  Double walled tanks will either have a "dry" or “wet” interstitial space which must be monitored on a monthly basis for the presence of product or product vapors, or in the case of a brine-filled interstitial space, the rise or fall of the brine solution which could indicate a leak in the inner or outer wall of the tank. 

My tanks are upgraded, do I have to continue to perform tank tightness tests?

Yes, a 5-year tank tightness test is still required if the tank owner uses liquid inventory control with monthly reconciliation. Tank owners have ten years from the date that upgrade requirements were met to switch to some form of monthly monitoring such as Statistical Inventory Reconciliation (SIR) or an ATG which performs a monthly 0.2 gallon/hour test. Double-wall tanks with interstitial monitoring do not have to be tightness tested. However, the monitoring system must be monitored annually.  See Federal Regulation 40 CFR 280.41.

I have a diesel system which is experiencing a bacteria growth problem, what can I do?

Most bacterial growth in tanks is due to water in the fuel.  Removal of the water, cleaning of the tank bottom and filtering the fuel will remove the bacteria and sludge in the tank.  Additionally, treatment of the fuel with an anti-fungicide will prevent future bacterial growth in the fuel. 

My pipeline has developed a leak do I have to replace the entire pipeline?

No. Performing a helium leak locate on the line will pinpoint the leaking portion of the line allowing for repair of only the leaking section.

When do I need to start monthly monitoring of my underground storage tanks?

The tank owner is required to start a monthly monitoring program ten years after upgrading an existing UST or installation of a new UST system . 

Monthly Monitoring Options are as follows;