Prior to putting a UST system designed to store ethanol blended fuels greater than 10% ethanol into service, tank owners must complete and submit an Ethanol Equipment Compatibility Checklist (CN-1285) and a Statement Of Compatibility (CN-1283) indicating the UST system components will be compatible with the product stored.
Ethanol blended fuels or E-blends are designated by the amount of ethanol the fuel contains. A fuel labeled as E-85 contains 85% ethyl alcohol and 15% gasoline. E-10 contains only 10% ethyl alcohol and 90% gasoline. With all the interest in alternative fuels, it is important to remember that not all components of most UST systems designed to contain and dispense petroleum products, may be compatible with alternative fuels such as ethanol blends.
The Division is charged with the safe storage of petroleum products (TCA 68-215-102) and E-blend fuels contain petroleum substances under the regulatory definition of petroleum. Therefore UST systems which store E-blended fuels are subject to all UST requirements. In addition, the Division is concerned about the compatibility of ethanol with UST system components designed to store much higher concentrations of petroleum substances. The division is not aware of any UST system components that are adversely impacted by interaction with fuels containing 10% ethanol. However, fuels containing 85% ethanol are now being marketed and the Division is concerned about the compatibility of UST system components with these high alcohol content fuels.
Dispensers are a critical component of the UST fuel system. Dispenser manufacturers sell dispensers that they certify to be fully compatible with E-blend fuels. This is the option the Division recommends for use with e-blended fuels.
If a tank owner wishes to use an existing dispenser with E-blend fuels, the installer must certify that all the listed dispenser components in Section 2 of the Ethanol Equipment Compatibility Checklist are certified by the manufacturer or UL Marked as compatible for E-blend fuel, by completing the checklist. If all the components are marked “Yes” then the dispenser is considered compatible with E-blended fuels.
If any of the listed components cannot be verified as either UL Marked or certified by the manufacturer as compatible, then the dispenser is not considered compatible with e-blended fuels. Dispensers that are not certified by the manufacturer or UL Marked as compatible for E-blend fuel must be inspected daily for leaks or equipment failure by using the Dispenser Daily Inspection Form (CN-1284). One form must be used for each dispenser or MPD (multi-product dispenser) connected to an E-blend tank. These records must be retained on site for a period of one year.
For more about Alternative Fuels you can visit the EPA website: https://www.epa.gov/ust/emerging-fuels-and-underground-storage-tanks-usts#tab-1