EPA Issues New Guidance on UST Pipe Dope Compatibility Requirements
October 9, 2018 | 
Iowa Guidance Already in Place
The 2015 EPA UST regulations require tank owners intending to sell ethanol and gasoline blends containing greater than 10% by volume ethanol to first demonstrate the ethanol and gasoline blends’ compatibility with specific UST system components. Interestingly, neither EPA’s direct rule nor supporting guidance references whether pipe dope or thread sealant is included in the components for which owners must provide proof of compatibility. Upon learning that pipe dope and thread sealant were not specifically listed by EPA as components requiring proof of compatibility, the PMAA UST Task Force, on which PMCI has a representative, approached EPA asking for guidance on the issue. The guidance is necessary because joints within a UST system are the second most common place within a system where leaks or even releases occur.
According to guidance issued by EPA last month, no affirmative compatibility determination is required for pipe dope. However, the original 1988 UST regulations require all UST system components to be compatible with the product stored, including pipe dope. As a result, according to EPA regulations a tank owner is not required to affirmatively demonstrate pipe dope compatibility. However, once a higher blend ethanol and gasoline product like E15 is entered into the system, the pipe dope must nevertheless be compatible with the product stored.
If you are confused with the interpretation above from EPA, you are not alone. Frankly, without PMAA’s intervention, EPA’s position on the issue put marketers in a position of peril with their respective financial responsibility providers. The good news for Iowa marketers is that, in 2011, PMCI and the Iowa DNR worked together to create a comprehensive equipment compatibility checklist for marketers that includes pipe dope and thread sealants. Because Iowa has an approved state underground storage tank program with EPA, Iowa’s requirements supersede the guidance issued by EPA. With many PMCI members analyzing their systems for compatibility with higher ethanol and gasoline blends like E15, be leery of anyone advising that pipe dope and thread sealant compatibility does not need to be determined prior to introducing it into your UST system.
