When I ask petroleum retailers if they have microbial problems in their fuel systems, almost always, the answer is: “No!”. After reading EPA’s recent report – Investigation of Corrosion Influencing Factors in Underground Storage Tanks with Ultra Low Sulfur Diesel Service – I felt better; sort of. The report’s Executive Summary states: “We observed 83 percent of the inspected tanks had moderate or severe metal corrosion. Prior to our research inspections, less than 25 percent of owners reported knowledge of corrosion in their UST systems.” It also observes: “Our research suggests that MIC is likely involved in the moderate or severe internal corrosion in USTs storing diesel.” For the uninitiated, MIC stands for “microbiologically influenced corrosion”.
Now think about this. Regardless of whether UST were fiber-reinforced polymer (FRP) or steel, the vast majority of UST tested had moderate to severe corrosion. Yet only 25% of site owners were aware of the problem. How is this possible? Perhaps we find one explanation in two, September 2016 PMAA Journal articles. Both report how PMAA leadership convinced the U.S. EPA to roll back their initial full set of routine system inspection items that were to be required under the 2015 revisions to the UST Regulations (40 CFR part 280). Interestingly, both articles focus only on the apparent savings site owners will realize. Neither article mentions that the repair and site remediation costs associated with fuel system leaks or failures: $250,000 to $500,000. Note that these estimates do not include revenues lost during site repair. Now let’s consider how many years of more thorough site inspection and condition monitoring one could get for a system failure that only cost $250,000. The PMAA Journal articles suggest a savings of approximately $4000/year/site. That translates into >62 years of more thorough condition monitoring that would reduce the risk of failure substantially. I think that it is particularly noteworthy that the PMAA Journal articles indicate that “PMAA is helping to revise the Petroleum Equipment Institute’s RP-900” in order to reduce the thoroughness and frequency of the walk through inspections detailed in RP-900. Is this a penny wise, pound foolish strategy? In my next post, I’ll discuss the problems with current fuel retail condition monitoring programs. Spoiler alert: I won’t be arguing that they are too burdensome or expensive.
