GTEC 2016 Management & Compliance Assistance Seminar

1. GTEC 2016 Management & Compliance Assistance Seminar August 25, 2016 Crowne Plaza – Atlanta Perimeter at Ravinia Discussion on EPA’s Report on the Investigation Of Corrosion-Influencing Factors In Underground Storage Tanks with Diesel Service Presented By: Howard Chesneau President Fuel Quality Services, Inc.

2. “EPA recommends that owners of underground storage tank (UST) systems storing diesel fuel check inside their tanks for corrosion, which research suggests is now appearing on equipment in most systems storing diesel fuel.” July 2016

3. “In 1986, Congress created the Leaking Underground Storage Tank (LUST) Trust Fund to address petroleum releases from federally regulated underground storage tanks (USTs) by amending Subtitle I of the Solid Waste Disposal Act.”

4. During that time a firm, Warren Rogers Associates, had developed a computer model to determine the probability of service station tanks developing a leak. They looked at several factors concerning the tank type and the tank environment. This was important because of the magnitude of the tank numbers and which tanks to examine first.

5. The investigation only involved the exterior of the fuel storage systems. The computer model categorized the probability of a tank developing a leak within 5 years. This allowed the Oil Companies and private owners the ability to work out a 5 year replacement plan based on the study.

6. There were also many presentations at various petroleum industry Conferences and meetings such as ASTM and IASH about the burgeoning recognition of Microbial Influenced Corrosion (now known as MIC). The down stream industry as a whole (except for Aviation) took this position.

7. 7 Years ago In late 2009, the failure of a dispenser pump at a fuel site near a marine environment led to the discovery of what appeared to be extreme corrosion. Information from a Presentation by Dan Liang Virginia DOT

8. The pump was only three months old and remarkably, what appeared to be rust coated some of the aluminum and plastic parts. Information from a Presentation by Dan Liang Virginia DOT

9. Information from a Presentation by Dan Liang Virginia DOT

10. TRosfelder: • Posted - 12/24/2007 :  08:55:56 • I have heard from a number of Pump & Tank contractors and maintenance technicians that they have experienced rusting and corrosion of submersible extractors and pump castings. In addition, they state they are experiencing STP check valve and dispenser shear valve seating problems due to the corrosion and impact to other materials. Pumping systems are losing pressure and thus causing slow pumping similar to thermal contraction. • Has anyone else experienced this ASTM Fuel Note date Presented by: Bob Renkes Petroleum Equipment Institute & Lorri Grainawi, Steel Tank Institute At an ASTM Fuel Corrosivity Workshop, Kansas City, MO July 1, 2010

13. Problems reported from all regions of the country • That means it’s not one refinery • And it’s not one pipeline • And it’s not one brand of fuel Presented by: Bob Renkes Petroleum Equipment Institute & Lorri Grainawi, Steel Tank Institute At an ASTM Fuel Corrosivity Workshop, Kansas City, MO July 1, 2010

14. Corrosion of Metal Components in UST Systems Storing Diesel Appears to be Common • Many Owners Are Likely Not Aware of Corrosion in their diesel UST Systems • The Corrosion is geographically widespread, Affects UST systems with Steel Tanks and with fiberglass Tanks, and Poses A Risk to Most Internal Components The Key Takeaways from the EPA Investigation

15. Ethanol Was Present in 90 Percent of the 42 samples tested, Suggesting Cross Contamination of Diesel Fuel with Ethanol is Likely the Norm, Not the Exception • The Quality of Diesel Fuel Stored in UST’s was Mixed • Particles and Water Content in the Fuel Were Closest to Being statistically Significant Predictive Factors for Metal Corrosion, but Causation Cannot be Discerned The Key Takeaways from the EPA Investigation

16. MIC Could be Involved as Hypothesized by Previous Research The data do not contradict the hypotheses suggested by CDFA’s 2012 study and EPA ORD’s research that MIC is occurring in UST’s when bacteria oxidize biofuels or residuals from biodiesel production found in diesel fuel. Previous research suggested that acid-producing bacteria, including those of the genus Acetobacter , and other acid-producing bacteria, can metabolize ethanol from switch-loading fuel delivery or biodiesel components of diesel such as glycerol and FAME breakdown products. In addition to bacteria, there are also a number of other microorganisms that could cause or contribute to the corrosion attacks including fungi, archaea and eukaryotic organisms. The Key Takeaways from the EPA Investigation

17. Preventing and treating MIC is recognized throughout industry as a standard recommended approach to maintaining UST systems The Key Takeaways from the EPA Investigation

18. Water, Water, Water Keep it OUT !!!!!

19. Regularly monitor and remove WATER present in the UST. • If possible filter fuel for water and particulates before it is delivered into the UST. or into a vehicle. Corrosion can occur there as well. • Use biocides to kill or prevent microbial colonies from actively attacking your fuel system. Recommendations

20. Preventive Maintenance does NOT mean fixing it after it breaks

21. https://www.epa.gov/ust/investigation-corrosion-influencing-factors-underground-storage-tanks-diesel-servicehttps://www.epa.gov/ust/investigation-corrosion-influencing-factors-underground-storage-tanks-diesel-service

22. Questions? remediation corrosion biological MIC fuel biocide testing water