Is this still an Interior Lining? -...

Celebrating 40 years of taking care of Missouri’s natural resources.

Is this still an

Interior Lining?

Heather Peters

Missouri Department of Natural Resources

[email protected]


New Federal Language 280.21

• Installed in accordance with 280.33

• Inspected on 10/5 year interval

If it is no longer performing in accordance

with original design specifications and

cannot be repaired in accordance with a

code of practice developed by a nationally

recognized association or independent

testing laboratory, then the lined tank must

be permanently closed…


But my lining isn’t for upgrades!

• Do you require inspection/ maintenance

for other linings?

• Compatibility?

• Repair?

• Secondary Containment?

• Do those regulations require I & M?


Interior Lining- Standards • American Petroleum Institute (API) RP1631

• National Leak Prevention Asso (NLPA) 631

• American Society for Testing and Materials

(ASTM) G158? – Purpose is for cathodic protection, not lining

• Underwriters Laboratory (UL)1856? – Construction NOT Inspection


API 1631 (Periodic Inspections)

• “Qualified person”

• Thickness/ Hardness checked

• Holiday detector for air pockets, leaks,

pinholes

• Steel tank integrity test required (must

have at least 75% original steel

thickness)


API 1631 (Periodic Inspections)

• Peeling

• Blistering

• Wrinkled

surface

• Defects repaired to manufacturer specs


NLPA 631 B Lining Inspections

• Certify employees…are knowledgeable

• Special inspector or qualified person

• Lining shall be tested:

– Signs of peeling, blistering, surface wrinkling

– Thickness/ Hardness/ Holiday testing

• Steel Integrity testing requirements (must

have at least 75%/85% original steel

thickness)


API 1631 and NFPA 631

• Both allow linings to be repaired

• Both require passing (75%) integrity

assessment of the steel tank

• Both have detailed breakdown of the

number and location of steel tank

measurements

• Does not allow mean-time-to-corrosion in

lieu of steel shell evaluation


Video Inspections????

• Ken Wilcox Associates Recommended

Practice for Inspecting Buried Lined Steel

Tanks Using a Video Camera

• Defines certified/qualified persons

• Signs of separation, delamination,

blistering, peeling, holidays

• Thickness/ Hardness test (minimum 5 at

each opening)

• Inspection only


Certifications?

• Confined Entry

• NACE International

– Coatings Inspector

• International Code Council (ICC)

– UST Installation/Retrofitting

• Society for Protective Coatings (SSPC)

• State specific?


UL1856- The New Retrofit Standard

1. Lining: single-walled

2. Upgrade: double-walled

– “Co-structural”: requires original “host” tank integrity

3. Self-structural: double-walled

– Does NOT require original “host” tank integrity

– Does NOT require steel tank to pass integrity test


Lining (UL1856)

• Single-walled

• Lining flush

against steel

• Steel

assessment in

standards


• Two walls of

the lining

• First layer

against steel

• Interstitial

space

• Steel integrity

required

Upgrade, double-walled


Self-structural

• Two lining

layers

• First layer

against steel

• Interstitial

space

• Steel integrity

NOT required


Inspections

Video/ Manned Inspection

• Every 5 years

• Assesses steel

• Assesses lining condition

• Failure only detected at

inspection (once in 5

years)

Interstitial Monitoring

• Continuous (NWGLDE def)

• Checks every day for 5

years

• Interstitial check catch

interior wall failure from

portion that contains fuel

• Exterior fail may be seen

• Does not assess condition

or approaching problems

• Detects failure immediately

?


Inspections and Monitoring Single-wall Lining

Video inspection

Entry inspection

5 year test

(only option)

Steel integrity

Double-wall Upgrade

Video inspection

(inside layer)

Entry inspection

(inside layer)

5 year test

Interstitial testing

? Steel Integrity

Can I even inspect it?

Self-structural

Video inspection

(inside layer)

Entry inspection

(inside layer)

5 year test

Interstitial testing

? Steel Integrity

Can I inspect it?

If steel doesn’t

matter, can I

exclude it?


Can I even inspection it?

• Lining: Yes, traditional inspection

• Double-walled co-structural:

– Video? Interstitial?

– If you allow G158 for steel assessment?

NOT INTENDED PURPOSE

• Self-structural:

– Inner layer only (if waive steel assessment)?

– If you allow interstitial? Video?


Steel Integrity Assessment

Can I do it? Must I do it?

Lining (single-walled) YES YES

Double-walled lining NO?? YES

Self-structural NO?? NO?? YES?


Is it eligible for repair?

Lining: Steel passes

Double-walled, co-structural:

If you allow mean-time-to-corrosion?

No repairs?

Self-structural: Manufacturer repair only? No

repairs?

Is a re-lining a repair? If okay to patch, but

prefer to re-line….

Patch?

But not

Re-line?

⤴

⤶ ⤶


Rules, Installs, Inspections

• Regulation: Inspect to industry standard

• Inspection Standard: Can repair IF steel

passes

• UL1856 Installation Standard: Steel is

irrelevant for Self-Structural

• What do I do?


Your Regs - Your SPA

• Opening Regulations

• Understand the standards

• What works for your state?

• Can you prove it is equitable?

• Talk to EPA about your SPA!


Questions- Now or End of the

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Is this still an Interior Lining? -...

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