pages, point customers to two shorter summaries released
by the EPA:
• The two-page executive summary, “Notice of
Corrosion Risks in Underground Storage Tanks Storing
• A three-page document written in plain English,
“Questions and Answers About Corrosion in
Underground Tanks Storing Diesel Fuel.”
2. Offering to develop a corrosion action plan for a
customer’s business. What maintenance and prevention
techniques should be implemented? What inspections
should be conducted? When? How? What reports can
you provide? An action plan should help a multisite owner
prioritize the inspections and follow-ups at those locations.
3. Keeping good records of ;ndings and actions. The need
for good records is obvious when you uncover moderate to
severe corrosion. Your ;ndings will suggest the nature and
extent of the steps you should take to address and solve the
problem. Inspections that do not uncover signi;cant corrosion also should be carefully documented. For example,
when you ;nd only minor corrosion that does not warrant
action, your observations will serve as a helpful baseline for
future inspections. Take photos of the metal components.
Write descriptions of what you saw. The next time you
come back to inspect, you will have a starting point from
which you can gauge the pace and severity of any new
WHAT’S NEX T?
In its report, the EPA cites an upcoming laboratory test
by the Coordinating Research Council (CRC), a nonpro;t
industry organization, on 11 factors that have been posited as
possible contributors to ULSD corrosion.
As of press time, the status of the CRC study (originally
planned for late 2016) remains uncertain.
Rick Long is general manager and associate
general counsel of PEI, as well as editor in
chief of the PEI Journal. Reach him at
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