T ask Order 3003, TDD #1, Standards , revised 10/27/08 1

Task Order 3003 , Subtask 3003 - 03c – Updating Standards and Standard - Making Groups TDD #1, Standards Summary of UST Technical Standards and St andard - Making Groups This report summarizes the methodology and findings of the review of t echnical standards an d standard - making organizations in the 1988 Federal Underground S torage T ank (UST) regulations . The complete results of the review are presented in the spreadsheet that accompanies this summary , “ TO 3003, TDD #1, Standards Review Spreadsheet, 10 - 16 - 08 .xls .” Th e spreadsheet has four worksheets:

 “40 CFR Part 280 Organizations,” which lists the organizations in the 1988 Federal UST Regulations, whether these organizations are still in existence, their total membership body , and Web site addresses for these organizations.

 “Potential Organizations,” which lists standard - making organizations that OUST may consider including in updated regulations, their total membership body , Web site address es , and the source of each potential organization (e.g., “s tandards drawer ,” state UST regulations , or Internet search).

 “40 CFR Part 280 Standards,” which lists the technical standards in the 1988 Federal UST Regulations, the organization that publishes each standard, the 1988 and current names and codes for these standards, if and when the standards were revised most recently , and the source for information on the standards.

 “ Potential Standards,” which lists the names and codes of technical standards that OUST may

consider including in updated regulations, the organization that publishes each standard, the latest edition, and the source of each potential standard (e.g., “standards drawer,” state UST regulations , or Internet search ). Methodology E 2 In c. reviewed the 40 CFR Part 280 U ST regulations and identif ied all ind ustry standards and associated standard - making organizations. E 2 In c. then located the organizations’ W eb sites to confirm their existence , determine their total membership body , and identify any updates to standards included in 40 CFR Part 280 . E 2 In c. requested th is information directly from three organization s that do not list this information on their W eb sites : the National Leak Prevention Association (NLPA), the Steel Tank Institute (STI), and Underwriter ’ s Laboratories of Canada (ULC) . To locate additional standards and standard - making organizations not included in 40 CFR Part 280, E 2 In c. reviewed the “ s tandards drawer” document provided b y OUST , searched UST program r egulatory documents from all 5 0 states and the District of C olumbia , and condu cted general Internet searches . All UST s tandards identified in theT ask Order 3003, TDD #1, Standards , revised 10/27/08 2

“ s tandards drawer” document and state regulat ory documents were located on the standard - making organizations ’ W eb si te s to determine the most current revisions . Unless a standard’s title indicated that it was not relevant to USTs (e.g. , it was clearl y related to aboveground storage t anks), all standards from the “s tandards drawer” and state UST regulations were included in the deliverables. Summary of Findings Determine whether each l isted standard

-making organization is still in existence and if so and possible

, determine the total membership body of the organizations. E 2 In c. identified 1 3 standard - making organizations listed in 40 CFR Part 280 , 12 of which are still in existence . One organization, the Association for Composite Tanks (ACT) , is now defunct. Two organizations still in existence have changed their official names: the American Society of Testing and Materials (ASTM) is now ASTM International and the National Association of Corrosi on Engineers (NACE) is now NACE International. Four of the 12 existing organizations do not have membership bodies . The spreadsheet that accompanies this summary reports the t otal membership body for the remaining eight organizations as des cribed on each organization’s Web site or as described through direct communication with the organization . Determine whether other applicable standard -making or

ganization s exist, an d if so and possible , the total membership body of the organizations. E 2 In c. identified 1 4 standard - making organizations not included in 40 CFR Part 280 through review of the “s tandards drawer” document, state UST regulatory documents, and general Internet searches. Of these 1 4 groups, nine were present in the “s tandards drawer” document, four were include d in state UST regulations (Florida and Alaska), and one was found through additional Internet searches . One organization included i n the “s tandards drawer” document, the Petroleum Association for Conservation of the Canadian Environment (PACE), no longer exists. Four of the 1 4 existing organizations do not have membership bodies. The spreadsheet that accompanies this summary reports the t otal memb ership body for the remaining 1 0 organizations as described on each organiz ation’s Web site. Determine whether industry standards have been updated and , if so, identify the latest revision . E 2 In c. identified 33 industry standards in 40 CFR Part 280. Nearl y all o f these standards have been revis ed or reaffirmed and have undergone name and/or code changes. Notable changes include :  Standard ACT - 100 “Specification for the Fabrication of FRP Clad Underground Storage Tanks” is now p ublished by the Steel Tank Institute as STI - ACT 100 - U F961 , “Specification for External Corrosio n Protection of Steel Underground Storage Tanks .”T ask Order 3003, TDD #1, Standards , revised 10/27/08 3

 ASTM D4021 “Standard Specification for Glass - Fiber- Reinforced Polyester Underground Petroleum Storage Tanks” was withdrawn in 1999 with no replacement .  NLPA Standard 631 now in cludes f our Chapters:  A - “Entry , Cleaning, Interior Inspection, Repair, and Lining of Underground Storage Tanks”  B - “Future Internal Inspection Requirements for Lined Tanks”  C - “Internal Inspection of Steel Tanks for Retrofit of Cathodic Protection”  D - “Lining of Fiberglass Tanks For Compatibility & Repairs That Are Allowed”

 American Petroleum Institute (API) RP1626 , “Storing and Handling Ethanol and Gasoline - Ethanol Blends at Distribution Terminals and Service Stations” is listed as out - of - print on the “s tandards drawer” do cument , but is currently available from the API W eb site. Identify other codes or standards not listed that may be used to meet regulatory requirements. E 2 In c. identified 1 73 potential standards not included in 40 CFR Part 280 through review of the “s tandards drawer” document, state UST regulatory documents, and general Internet searches. Of these 1 73 standards , 1 2 8 were present in the “s tandards drawer” document, 3 5 were f

ound in state regulations, and 10 were found during additional Internet searche s . Notable f indings include :  Six states include National Fire Protection Association (NFPA) 329 , “Handling Releases of Flammable and Combustible Liquids and Gases” in their UST regulations. NFPA 329 is l isted in the “s tandards drawer” document.

 Fourte en states include NFPA 3 0 A , “Code for Motor Fuel Dispensing Facilities and Repair Garages” in their UST regulations. NFPA 30A i s listed in the “s tandards drawer” document.

 Seven states include NACE TM0497 , “Measurement Techniques Related to Criteria fo r Cathodic Protection on Underground or Submerged Metallic Tank Sy stems” in their UST regulations. NACE TM0497 i s listed in the “s tandards drawer” document.

 Seven states include API RP 1637 , “Using the API Color- Sy mbol Sy stem to Mark Equipment and Vehi cles for Product Identification at Service Stations and Distribution Terminals” in their UST regulations. APIRP 1637 is listed in the “s tandards drawer” document.T ask Order 3003, TDD #1, Standards , revised 10/27/08 4

 Six states include STIR892 , “Recommended Practice for Corrosion Protection of Underground Piping Networks Associated with Liquid Storage and Dispensing Sy stems” in their UST regulations. STI R892 is listed in the “s tandards drawer” document.

 Fifty- four standards listed i n the “s tandards drawer” document (including the f ive listed above) are included in at least one state’s UST regulations.

 Four Military

standards listed in the “standards drawer” document are included in the “Potential Standards” worksheet but do not have associated organizations listed in the “Potential Organizations” worksheet .