The fuel supply in the United States is continuously evolving. Fuel today incorporates more ethanol than before. Ethanol is a renewable fuel made from various plant materials collectively known as "biomass." More than 98% of U.S. gasoline contains ethanol, typically E10 (10% ethanol, 90% gasoline), to oxygenate the fuel and reduce air pollution.
UST and fuels stakeholders found that some installed UST systems were incompatible with lower level ethanol blends. The UST system equipment industry responded to the increasing use of biofuels and the risks identified by creating equipment compatible with the lower blends of these fuels.
Gradually, the industry began to make higher blends of ethanol and biodiesel compatible equipment. The EPA assures that the tanks and piping produced now are compatible with up to 100 percent of ethanol and biodiesel blends.
The 2015 UST regulation lists the steps UST owners and operators must take to protect our health and environment from UST releases
due to incompatibility. These steps will also aid in avoiding the cost of cleaning up releases and legal actions that may occur if your UST system releases product to the environment.
How Do You Demonstrate Your UST System Compatibility?
There are two options available to demonstrate that your Underground Storage Tank system is compatible with biofuels, according to the UST 2015 Regulation.
- Certification of the listing of UFT system equipment or components for use with the regulated substance stored by a nationally recognized, independently testing laboratory;
- Approval by the manufacturer of equipment or component. The approval must:
a) be in writing,
b) include an affirmative statement of compatibility,
c) specify the range of biofuel blends the component is compatible with, and
d) Be from the manufacturer of the equipment or component
Additionally, it is essential to keep the compatibility documentation stored.
All compatibility demonstration documents for all UST system equipment and components that come into contact with the substance must be kept safe.
An Alernative Method of Meeting Compatibility Requirements
The UST Regulation 2015 allows implementing agencies to determine alternative methods that meet the compatibility requirements for USTs.
The methods must determine the compatibility level of regulated substances, such as, substances containing more than 10 percent ethanol, substances containing more than 20 percent biodiesel, and any other substance identified by the agency.
However, these methods must be no less protective for human health and the environment.
Which Records Must be Stored
Ever since the UST 2015 regulation, the law requires you to keep records that show your UST system is compatible with the updated regulation. You must keep these records as long as you store such substances, namely substances containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any other substances identified by your implementing agency.
Additionally, records of any repairs to such equipment or components are also deemed necessary to be stored. Such documents might be required to demonstrate the UST product and equipment compatibility.
Functionality vs. Compatibility for Release Detection Equipment
Higher blends of fuel have the potential to affect both, adversely, the functionality and the compatibility of the equipment.
Ethanol can dissolve with water, affecting the amount of water absorbed or retained in fuel. Release detection devices use sophisticated technologies to evaluate product levels in underground storage tanks, and ethanol mixing with water disrupts them from functioning efficiently.
UST owners should ensure that their release detection equipment is also compatible with the stored biofuel and meets EPA’s release detection performance standards for use with biofuel.
Upgrading Equipment to Meet Compatibility Requirements
UST owners and operators that operate from before UST regulation 2015 might not be able to demonstrate the compatibility requirements for storing high blends of biofuels. These owners have three options:
The first option is to use targeted retrofits of specific equipment of current UST that needs upgradation.
Owners that will be able to demonstrate compatibility for the tanks and pipelines can upgrade other components of the UST system and save operational downtime, given that the documentation is present for the compatibility.
Pipelines and tanks are the most expensive components of a UST system, and no upgradation in both these components also prevents breaking the concrete pad that covers the system.
The second option is to install a new UST system that is compatible with the substances. An owner should specifically request equipment compatible with substances that contain greater than 10 percent ethanol or greater than 20 percent biodiesel. The upgrade cost of compatible equipment is less than the cost of an overall change of a UST system. However, the owners must request such equipment before installation.
The last option is not to store the substance entirely. This will ensure no occurrences of substance due to incompatibility. This also saves the owner from compliance issues and cleaning issues that result from a release from an incompatible system.
Additionally, owners are also advised to take online courses that aid in understanding and dealing with the situations they may face in a UST system. For example, the Texas Class A and Class B UST Facility Operator Training Course