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UST System Compatibility Determination for Ethanol Blends Greater Than E10 and Biodiesel Blends Greater Than B20

 

As interest grows among retailers in the marketing of higher blends of ethanol and biodiesel, FUELIowa would like to remind members of the processes to follow and the pitfalls to avoid when introducing those products into your UST system.  Prior to introducing E15 or a biodiesel blend containing greater than 20 percent by volume biodiesel, FUELIowa members must conduct a UST equipment compatibility assessment using Iowa DNR Form 542-1336 and notify the Iowa DNR UST Section of your intent to introduce a new product through your equipment. 

Pipe dope and thread sealants have come under scrutiny after EPA inexplicably left these system components off of the list of components for which a compatibility determination was required in EPA’s 2015 revisions to their underground storage regulations.  The failure by EPA to include these components in their list of components for which a compatibility determination is required has led to the spread of misinformation by interested parties and confusion among marketers.  Despite being left off of EPA’s compatibility checklist, Iowa DNR Form 542-1336 requires identification of pipe dope and thread sealants and an accompanying compatibility determination.  This determination is critical for marketers because of the general requirement in 40 CFR 280.32 that the UST system be compatible with the substance stored and the potential ramifications for marketers with not only their regulatory agency but also their financial responsibility provider if the components are not compatible.

Recently, EPA has offered additional information clarifying their findings regarding the compatibility of pipe dope and thread sealants commonly used in the marketplace.  EPA’s findings echo what FUELIowa associate members have shared with FUELIowa staff.  According to the EPA, compatible pipe dope is currently available but much of the pipe dope on the market is not.  Ensuring UST systems are compatible with the pipe dope and sealant used is critical because EPA thinks that pipe dope used prior to 2007 is probably not compatible with ethanol blends greater than 10 percent. Most older pipe dope was soft set pipe dope and not intended to be used with ethanol blends over 10 percent. This means an owner or operator considering storing regulated substances containing greater than 10 percent ethanol in a system, which was not explicitly installed with the intent of storing regulated substances with greater than 10 percent ethanol, will presumably need to modify each threaded connection point where pipe dope seals the threads to meet the UST system compatibility requirements in 40 CFR 280.32.

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