How can owners and operators of existing USTs with copper piping meet the piping upgrade requirements?

The underground storage tank (UST) regulations in 40 CFR Part 280 require existing USTs to meet new tank requirements, complete upgrade requirements, or close by December 22, 1998 (Section 280.21). A component of the upgrade requirements includes upgrading metal piping that routinely contains regulated substances and is in contact with the ground.

Owners and operators can meet the piping upgrade requirements of Section 280.21(c) by ensuring that copper piping is cathodically protected in accordance with a code of practice developed by a nationally recognized association or independent testing laboratory and meets the requirements in Sections 280.20(b)(2)(ii), (iii), and (iv). Sections 280.20(b)(2)(ii),(iii), and (iv) require that field-installed cathodic protection systems are designed by a corrosion expert, that impressed current systems are designed to allow determination of current operating status as required in Section 280.31(c), and that cathodic protection systems are operated and maintained in accordance with Section 280.31 or guidelines established by the implementing agency. In addition, owners and operators may use a variety of other codes and standards referenced in the note at Section 280.20(b)(2) to comply with the requirements of Section 280.20(b)(2). These standards include the National Association of Corrosion Engineers Standard RP-01-69, “Control of External Corrosion on Submerged Metallic Piping Systems,” which specifically addresses cathodic protection for copper piping.