b' Marketer InformationRules & Regulationscontinued from page 7difficult if not impossible. There are three ways to demonstratewith secondary containment and interstitial monitoring for tanks E15 compatibility of UST components under EPA regulations: and piping (including safe suction piping). The EPA explains thatE15 compatibility certification by proof of E15 compatibility is not necessary in these cases because secondarily contained tanks and piping with interstitial monitor-Underwriters Laboratories (UL)ing will detect a potential leak from noncompatible equipmentE15 compatibility certification by manufacturersbefore it reaches the environment. All states now require sec- Any alternative method adopted by a state that is equally protec- ondary containment and interstitial monitoring for all new and tive of the environment as UL and manufacturer certification. preplaced UST systems. The EPA calculates that 24% of all UST None of these methods prove wholly satisfactory for demon- systems nationwide are equipped with both double-walled tanks strating E15 compatibility with existing E10 compatible USTand piping. The EPA believes all of these systems should be able systems. First, UL only certifies newly manufactured equipment.to use interstitial monitoring in double-walled components, though UL refuses to recertify existing E10 equipment for E15 use.some may currently use a different release detection method. Second, manufacturers have recertified very few E10 components as E15 compatible. The relatively few E10 UST componentsCompatibility Based on Identified UST Componentsre-certified for E15 is insufficient to address the wide variety ofThe EPA has identified certain categories of equipment where UST equipment in the ground today. Even if manufacturers weretank owners would not need to demonstrate compatibility with able to recertify the majority of E10 UST components for E15higher ethanol blends including:use, many marketers would still be unable to prove compatibility All steel and fiberglass tanks manufactured after 2005due to lack of documentation needed to identify manufacturer andAll fiberglass reinforced pipingmodel number of existing equipment. This is particularly true forAll equipment certified by manufacturers andthe pipe dope and adhesives holding the system together, which are the most susceptible to the corrosive effects of E15. Installersindependent laboratoriesuse an array of different pipe dope and adhesives interchange- Compatibility Based on Individual Models of Equipment ably that are rarely identified by brand name or manufacturer onAlready Known to be Compatibleinstallation or repair documentation. No state has come up withThe EPA has identified certain equipment models by manufactur-an alternative method to demonstrate E15 compatibility. Norers that are already known to be compatible with higher blends of are they likely to do so any time soon. Most state Fire Marshals,ethanol after certain production dates. This equipment includes:insurance providers, and state UST insurance funds oppose any changes that would weaken current compatibility requirementsSingle-walled fiberglass tanks, 1995 model year and beyond Double-walled fiberglass tanks; 1990 model year and beyond due to the increased risk of a release that would result.Flexible piping, 2011 model year and beyond Proposed ChangesFiberglass containment sumps, 1995 model year and beyondto UST Compatibility RequirementsPumping equipment, 2010 model year and beyondSpill equipment, 2015 model year and beyondE100 CompatibilityRelease detection equipment, 2006 model year and beyond In the NPRM, the EPA proposed that all newly installed UST Overfill equipment, 2006 model year and beyond systems and all replacement parts for existing systems be compat-Some models of unlined single-walled steel tanks, no date ible with ethanol blends up to E100. The E100 mandate applies Some models of unlined double-walled steel tanks, no date to all UST systems regardless of the ethanol blend they currently store or will store in the future. This means that energy marketersConclusionplanning to sell blends no greater than E10 will nevertheless beEMA opposed all aspects of the NPRM due to the heavy com-required purchase E100 compliant equipment when replacing anypliance cost burden it would impose on small businesses, and existing UST component or installing a new UST system. Thethe significant increase to the risk of liability from E15 con-EPA believes replacing E10 equipment with E100 componentssumer misfueling. If approved as a final rule, the NPRM could will result in only a minimal cost increase for tank owners.also bankrupt state tank funds due to a sharp rise in additional Compatibility Based on Secondary Containment claims for releases from USTs that are not compatible with E15 The EPA is also proposing to allow tank owners who cannotblends. The NPRM also raises some serious questions for energy demonstrate compatibility of existing UST systems with E15 tomarketers. Do the proposed changes in the NPRM help market-forgo proof altogether provided for these systems are equippeders with E15 compatibility proof in a practical way or are they not useful given the real world compatibility issues raised by 52 www.wpma.com / Summer 2021'