- What is cathodic protection?
- Are my underground storage tanks in compliance
with EPA regulations?
Do I have to test my pressurized product lines and how often?
Do I have to test my line leak detectors and how often?
Which type of suction line do I have to test, and when?
If I have cathodic protection on my fuel system how often do I
have to test it?
Does my automatic tank gauge have to be tested each year?
If my leak detector starts triping or goes into alarm do I
have a leak?
Can tanks which are older than 10 years be upgraded with
I have double wall fiberglass tanks, do I have to perform leak
monitoring on the tank?
My tanks are upgraded, do I have to continue to perform tank
My diesel system is experiencing a bacteria growth
problem, what can I do?
My pipeline has developed a leak do I have to replace the entire
When do I need to start monthly monitoring of my underground
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
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
Are my underground storage tanks in compliance
with EPA regulations?
Most regulated tanks should comply with three regulations:
- A leak detection system;
- A spill containment basin;
- 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
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.
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.
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.
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).
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.
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.
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.
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.
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
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.
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.
No. Performing a helium leak locate on the line will pinpoint the
leaking portion of the line allowing for repair of only the
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;