EPA has previously defined the necessity of keeping tank material verification records on site. In recent months, vendors and operators in the state of Texas have reported a rash of alleged violations surrounding this requirement. If you have sites in Texas and don’t have these records available upon inspection by the TCEQ/UTA, prepare to receive an NOV.

As stated in 30 TAC 334.49, owners and operators must maintain all corrosion protection records for Cathodically Protected tanks. Installation records should be maintained as long as the system is used, including:

  • The name, address, telephone number, and Corrosion Protection credentials of either the company which designed the factory-installed Cathodic Protection system or the corrosion specialist who designed the field-installed Cathodic Protection system, as applicable.
  • Drawings or plans depicting the locations of all Cathodic Protection system components, including the locations of all test stations.
  • Operating instructions and warranty information, maintenance schedules, and testing procedures for all operational components of the Cathodic Protection systems.
     

Corrosion Protection testing and inspection records should be maintained for at least 5 years after the test date or inspection.

If no Corrosion Protection system is installed, be prepared to provide one of the following to verify a non-corrosive tank material is present.

FRP tanks:

  • Original invoice from the tank manufacturer, showing brand and model delivered to the site
  • Written statement from the original UST Contractor who installed the tanks, stating the brand and model installed at the facility.
  • Written statement from a registered UST Contractor, along with a photo of an external portion of each tank (visible through manway or sump, or through partial excavation), documenting the tank exterior is FRP construction and reinforcement ring is present, or a photo of factory applied tag or label showing tank brand and model (UL-1316).
  • Written statement from a NACE Specialist or Professional Engineer, stating a properly performed magnet test shows tanks to be non-metallic.
  • TCEQ Regional Office installation inspection records showing brand and model of each installed tank at the site.
  • Written statement from company providing internal camera survey of each tank, stating each tank is FRP, along with supporting photographic evidence.
  • Written statement from NACE specialist, stating that Corrosion Protection is not necessary for each tank and line system at the site.
     

Clad/Composite or Jacketed Steel tanks:

  • Original invoice from the tank manufacturer, showing brand and model delivered to the site
  • Written statement from the original UST Contractor who installed the tanks, stating the brand and model installed at the facility.
  • Written statement from a registered UST Contractor, along with a photo of an external portion of each tank (visible through manway or sump, or through partial excavation), documenting the tank exterior is FRP construction and shows a factory applied tag or label showing tank brand and model (ACT-100, UL-1746 Part II, UL-1746 Part III, or STI Permatank).
  • TCEQ Regional Office installation inspection records showing brand and model of each installed tank at the site.
  • Written statement from NACE specialist, stating that Corrosion Protection is not necessary for each tank and line system at the site.
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