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Task Order 3003

– General Technical and Programmatic Support for Regulatory Development T echnical D irective Number 17 , Task 2, S ubtask e
– Internal Lining Failures

Summary of Internal Lining Failure Analysis

July 2 9 , 200 9 1.0 Background This summary

doc ument reports the methodologies and findings of an information review related to the internal linings of underground storage tanks (USTs). One appendix is also included (Appendix A: L ining Inspection Company Contact Li st). 2.0 Internal Lining Failure Su mmary Methodology B y contacting not more than nine lining inspection companies 1 

### , E2 Inc. determined:

 The total number of lining inspection s conducted by the companies over the past ten ye ars (1999

- 2009)

.  The number of the companies’ lining inspectio ns th at did not pass inspection.

 The number of the lining inspection failures identified that could be repaired in accordance with a code of practice.

 The number of the lining inspection failures identified that could not be repaired in accordance with a code o f practice. The contractor used the PEI W eb site ( www.pei.org ) and general Internet searches to develop a list of potential lining inspection companies. E2 Inc. reviewed the list with the EPA subject matter expert befor e finalizing the list of nine companies. Results Eight of the nine lining inspection companies contacted provided information estimates

. The other company (Tank Liners) no longer provides lining inspections and was not able to provide any data

. F ive co mpanies estimate d the total number of lining inspections that they have conducted over the past ten years. The other three companies were able to provide an estimate for the past ye ar . T hese companies indicated that annualizing that number over the past decade would be the best way

to estimate the total number of lining inspections that they had conducted. For these companies, the contractor multiplied their annual estimates b y ten. Four of the companies conduct fewer than 100 lining inspections annu ally

. One compan y ( Tank Tech) is a high

- volume inspector, conducting approximately 1,0 00 lining inspections annuall y (Table 1)

. The four companies that conduct at least 100 inspections annually estimated the percentage of lining inspection failures at be tween five percent and 16 percent. The four companies that conduct fewer than 100 inspections annually had a wider estimate range for the number of lining inspection failures: between seven percent and 57 percent (Table 1)

.

1 In order to comply with the Paperwork Reduction Act, no more than nine contractors were contacted.

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Of the six companies that prov ided estimates regarding the number of lining inspection failures that could be repaired in accordance with a code of practice, 50 percent was the lowest estimate provided for the percentage of these linings that were repairable. Four companies indicated that at least 7 5 percent of the linings were repairable, with one of these companies stating that virtually all linings (99 percent) were repairable (Table 1)

. Multiple companies stated that most tanks can be repaired, but that many repairs are cost

- prohibitive, with replacement recommended as the alternative approach. Taken together, the companies contacted estimated that they have conducted a total of 15,590 lining inspections over the past ten years, or 1,559 annually (Table 1 ). In total, the companie s estimated that 12 percent (1,800

– 1,850) of these USTs did not pass lining inspections (Table 1). Of these USTs, the companies estimated that 77 percent (1,307

– 1,352) could be repaired in accordance with a code of practice (Table 1). The companies es timated that twenty

- three percent (384

– 389) of these USTs could not be repaired in accordance with a code of practice (Table 1). These compan y estimates were then extrapolated to the total number of USTs in the United States (Table 1). Based on UST data from TO 3003, TDD #5, it is estimated that five percent (30,831) of the 616,613 USTs in the United States are lined USTs that could have had lining inspections conducted over the past ten ye ars (Table 1). Twelve percent (3,700) of these USTs may not have passed lining inspections (Table 1). Of these USTs, 7 7 percent (2,849) could have been repaired in accordance with a code of practice (Table 1). Twenty- three percent (851) of these USTs would not have been repairable in accordance with a code of practice (Table 1). Annualized, lining inspections could have been conducted for a total of 3,083 USTs each year (Table 2). There could have been 370 USTs each year that may not have passed the l ining inspections (Table 2). Of these USTs , there could have b een 285 that could have been repaired in accordance with a code of practice and 85 that could not have been repaired in accordance with a code of practice (Table 2). The interviews also provided some additional inf ormation that may

be of interest to O UST:

 According to s everal companies , new regulations and state laws are the primary driver of the lining inspection process, leading to updated codes of practice.

 The repairability

of tank linings varies from state to state ( i.e., lining regulations in o ne state may mandate the replacement of a tank, whereas that lining would be repairable in a neighboring state )

. Pennsylvania, for example, does not permit the repair of UST linings.

 Several companies anticipate that the failure rate of tank linings will drop over time, because the quality

of tank linings and lining repairs has improved significantly over time. One exception, according to one company: the increased storage of ethanol in USTs has led to an i ncrease in tank lining failures

.

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Table 1. Linin g Inspection Failure and Repair Findings

Lining Inspection Company Total Number of Lining Inspections Conducted Over Past 10 Years Number / %

of Lining Inspections That Did Not Pass Inspection Number / % of

These Lining Inspections That Could Be Repaire d in Accordance with a Code of Practice Number / % of These

Lining Inspections That Could Not Be Repaired in Accordance with a Code of Practice Advanced Fuel Systems 140 80 / 57% 40 / 50% 4 0 / 50% AmT ech Tank Lining & Tank Repair 1 , 000 50

– 100 / 5%

- 10% 45

– 90 /

90% 5

– 10 / 10% Center Point Tank Services 100 10 / 10% data not available* data not available* Fuel Tank Maintenance 450 250 / 56% 125 / 50% 1 25 / 50% Northwest Tank Inspecti ons 900 60 / 7% 59 / 99% 1 / 1% Tank Liners company no longer conducts inspections and did not provide data Tank Tech 10,000 1,000 / 10% 85 0 / 85% 150 / 15% Tanknology 1,400 100 / 7% data not available* data not available* WCC Tank Technology 1 ,6 00 250 / 1 6 % 188 / 75 % 6 3 / 25 %

Totals: 15,590 1,800

– 1,850 / 12% 1, 307

– 1, 35 2 /

77 %  384

– 389 /

23%  Extrapolated Findings % of Lined Tanks in United States (Estimate fromTO 3003, TDD #5) Total

Number of USTs in United S tates Extrapolated

Number of Tanks That Could Have Had Lining Inspections Conducted Over Past 10 Years Extrapolated

Number / % of These Lining Inspections That Did Not Pass Inspection Extrapolated

Number / % of These Lining Inspections That Could Be Repair ed in Accordance with a Code of Practice Extrapolated

Number / % of These Lining Inspections That Could Not Be Repaired in Accordance with a Code of Practice

5%  616,613  30,831 3,700 / 12% 2,849 / 77% 851 / 23% Note: data provided by all companies cont acted are estimates. Due to rounding, some numbers will not total as expected. * c om pany does not repair linings.  Lining inspections conducted by Center Point Tank Services and Tanknology not included in estimate, due to lack of data availability.  Estimate from TO 3003 , TD D #5 . Estimate from review of UST equipment currently in use for federally regulated USTs in 23 states.  UST Corrective Action Measures Report for Mid

- Year FY 2009

.

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Table 2 . A nnualized Data Totals f rom Lining Inspection Company Interviews and Data Extrapolation Annualized Number of Lining Inspections Conducted Over Past 10 Years Annualized

Number / % of Lining Inspections That Did Not Pass Inspection Annualized

Number / % of These Lining Inspections That Could Be Repaired in Accordance with a Code of Practice Annualized

Number / % of These Lining Inspections That Could Not Be Repaired in Accordance with a Code of Practice Annualized Lining Inspection Com pany Interview Data 1,559 180

– 185 / 12% 131

– 135 /

77% 38

– 39 /

23% Annualized Extrapolated Lining Inspection Data 3,083 370 / 12% 285 / 77% 85 / 23%

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Appendix A. Lining Inspection Company Contact List Lining Inspection Company Date s of Contact Contact Method and Information Advanced Fuel Systems Co lumbus, OH www.advfuel.com 06/29/09 07/07/09 Steve Thickstun e - mail: steve@advfuel.com
AmT ech Tank Lining & Tank Repair Plymouth, NH www.armorshielding.com 06/25/09 07/02/09 Dennis Paquet telephone: (888) 839

- 0373
Center Point Tank Services Douglasville, PA www.cptank.com 06/29/09 06/30/09 07/02/09 Roger Tartaglia telephone: (610) 385

- 4977
Fuel Tank Maintenance Cookeville, TN www.fueltankmaintenance.com 06/29/09 07/06/09 07/11/09 07/15/09 Brandon Mack telephone: (931) 528

- 1137
Northwest Tank Inspections Vancouver, WA 07/09/09 Scott Border s telephone: (360) 253

- 3619 Tank Liners Beaverton, OR www.tankliners.com 06/25/09 07/02/09 07/07/09 07/15/09 07/21/09 e - ma il: albert@tankliners.com telephone: (503) 965

- 4678

Tank Tech Blodgett, MO (headquarters) www.tanktech.com 06/25/09 07/02/09 07/05/09 Rob Russell telephone: (573) 471

- 1932 Tanknology Austin, TX (headquarters) www.tanknology.com 06/25/09 06/30/09 07/02/09 Bert Schutza

e - mail: bschutza@tanknology.com WCC Tank Technology New burgh, NY 06/25/09 07/02/09 07/15/0 9 07/17/09 07/20/09 Bob Deitz telephone: (845) 564

- 9555 e - mail: wcctank@yahoo.com