ZCL | Xerxes sells underground tanks to a variety of industries, including petroleum. In July 2015, the Environmental Protection Agency (EPA) revised its underground storage tank regulation originally adopted in 1988 (Code of Federal Regulations, 40 CFR Part 280). The goal of the regulation is to prevent underground storage tanks from leaking and contaminating the groundwater. Among the requirements, tanks must provide cathodic protection and be double-walled so they can be monitored.
While the EPA regulation addresses the more than 550,000 underground tanks nationwide that store petroleum and other hazardous substances, there are a plethora of other regulations – mostly state and local – that provide what Coe calls “built-in growth opportunities” for tank suppliers. And they extend beyond tanks for caustic gases and liquids.
“Today, those regulations happen in the water industry as well,” says Coe. “Jurisdictions across the country are requiring new construction to incorporate water reuse.” For instance, properties over a certain size in California will have to collect the water used in sinks, showers and toilets in the building, clean it on-site and reuse it to flush toilets or irrigate the land once SB 966 is implemented. (The bill was signed into law by Governor Brown in September 2018.)
A social media company in northern California ordered five underground tanks from ZCL | Xerxes to accommodate its on-site wastewater treatment system at two new buildings. The goal was to treat between 40,000 and 50,000 gallons of waste a day, which would then be used for all the company’s non-potable demands, including toilet flushing – the largest consumption of water in any business office.
“Technology firms are very progressive in their management of water, and the composites industry benefits from that because they want something that will last the life of the building,” says Coe.
ZCL | Xerxes has moved into another area where regulations are beginning to play a large role – the storm water business. “Storm water is what hits the pavement, and rainwater is what hits the roof,” says Coe. “The difference between the two is one has hydrocarbons and one does not.” Storm water runoff can include oil, grease, pesticides, nitrogen and other contaminants.
Local governments are starting to enact regulations to mandate the retrieval of storm water before the polluted water hits a stream, river, lake or other water source. Most of the focus on storm water is in regions along water, such as the Atlantic and Pacific coastlines.
“The old adage is all politics are local,” says Coe. “In water, all regulations are local.” The Clean Water Act, enacted in 1972, is the primary federal law governing water pollution. However, it has never been fully enforced and continues to be a source of political friction. The U.S. Supreme Court heard arguments in November in a case (No. 18-260, County of Maui, Hawaii v. Hawaii Wildlife Fund) that could settle a portion of national water regulations – and greatly impact the tank industry.
The Importance of Solid Design
One unintended consequence of regulations is the tendency of designers and engineers to become conservative and over-design tanks. Lambrych encourages industry professionals to be champions of FRP and appropriate design. He cites temperature requirements as one example: “Oftentimes there is a maximum operating temperature [for tanks] and a design temperature,” he says. “There’s a struggle when engineers put a safety factor on top of a safety factor. The next thing you know, you have a design temperature that doesn’t make much sense for the FRP or the process [the customer] is running.”
Over-design also occurs when customers aren’t knowledgeable about composites. Plas-Tanks recently fabricated three tanks, 13 feet in diameter and 31 feet long, for a chemical manufacturing plant in the Middle East to store hydrochloric acid. In addition to the tanks, the company produced GFRP saddles to support the horizontal tanks. “Our saddles are typically hollow inside, but the end user was hesitant to use hollow saddles,” says Puthoff. “They didn’t think it would be supportive enough, so we are filling the saddles with resin to provide additional strength properties. It isn’t required for support, but it will give the end user ease of mind.”
In Clarkson’s experience, when tanks fail it’s often not the fault of the material or construction. “A lot of problems that people have with FRP are related to how the tank was installed in the facility and what happened to it – things like process upsets, where there was a temperature excursion or a pressure spike,” he says.
Working hand-in-hand with designers and engineers during the design process can help combat process upsets and other on-site failures, in addition to curtailing over-design. “It’s worthwhile for manufacturers to really quiz end users on their process controls,” says Clarkson. For example, if fabricators ask customers to fully explain where and how the tanks will be used, then they may be able to offer design advice to head off potential problems with temperature deviations, pressure spikes and other issues.
“A number of failures or near failures we’ve observed have occurred because somebody took a short cut at the design stage,” says Clarkson. “It’s in the best interest of the buyer to have somebody go through the details and look at how the equipment is put together, installed and used.”
A well-designed, well-made FRP tank can be virtually maintenance-free and last for decades. “Composite tanks are lasting a long time – and can last even longer,” says Clarkson. “But we have a significant need globally to give good advice on fitness for service and the ability of a storage tank to stay in service.”
Collaboration Is Key to Market Growth
The best way to advance the use of composites in the tank market is for industry experts to work together with their peers, as well as engineers, designers, consultants and others in the market. Both Schoessel and Puthoff are part of a group that meets twice a year to discuss the American Society of Mechanical Engineering’s RTP-1 standard for reinforced thermoset plastic vessels. The group has open discussions about end user needs where members share ideas. It also has a sub-committee dedicated to marketing, which is planning a conference to educate engineers about FRP tanks.
“Working with engineering firms is important because ultimately they are the ones writing the specifications we have to adhere to,” says Puthoff. “We need to educate them on composites versus alloys and other materials.” INEOS strives to educate engineers, as well as industry partners, through its Corrosion Science Center (CSC). The goal of the CSC is to grow the usability and profitability of FRP composites in corrosion-resistant applications. It has held lunch-and-learns with engineering firms like FLSmidth & Co. to share advice on topics such as maintaining FRP equipment and identifying a third-party inspector.
Ultimately, sharing ideas and knowledge rather than working in individual silos remaining tight-lipped about your expertise will benefit the entire composites industry. Says Puthoff, “There’s a much larger market share out there that could keep all of us busy if we work together.”