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CONHOINTIAL Section 1 Introduction The Industrial Environmental Coatings Corporation (IECC) has developed a tank lining system, referred to as the EC 125 (or EC 125U, a slightly modified chemical composition that is compatible with methanol and ethanol) system for installing in an underground storage tank. This lining is made of an epoxy matqW, is sprayed onto the interior of a prepared tank, is allowed to cure, and is tested. California, and perhaps other states or municipalities, require that certain aspects of lining systems be certified by an independent third party. One of these aspects is that the lining process "be listed or certified by an independent testing organization based on voluntary consensus standards." The voluntary consensus standard, in this case, is indicated by the State of California to be the American Petroleum Institute (API) Recommended Practice API 1631, "Interior Lining of Underground Storage Tanks," Third Edition, April 1992. In the Preamble to 40 CFR 280 (pages 37131, 37132, and 37139 of the 1988 Federal Register), the EPA expressed the opinion that with the addition of lining, the life of a bare steel tank can be extended at least ten (10) years with leak free performance. The final rule [40 CFR 280.21(b)(1) and 280.33(a)]-incorporates the EPA conclusion and references codes and standards that may be used to comply with the upgrade requirements and repairs allowed. The IECC fining process meets or exceeds the requirements of the accepted industry standard presented in the American Petroleum Institute (API) Publication 1631, "Recommended Practice for the Interior Lining of Existing Steel Underground Storage Tanks," as required by the Federal EPA Standard. Therefore, the internal fining should be expected to extend the life of a steel underground storage tank by at least 10 years. It is to be noted that the state of California requires that the repair material also be certified relative to meeting voluntary consensus standards (such as those in API 163 1) concerning materials compatibility with products to be stored in the tanks. The materials compatibility is a subject not covered by this report. The evaluation of the IECC lining process by Midwest Research Institute (MRI) is the subject of this report. Section 2 contains a comprehensive analysis of the IECC Technical Specification, "Recommendations for Internal Lining and Repair of Underground Storage Tanks," December 1994 as revised February 1995, comparing these published procedures with the API 1631 Recommended Practice. Section 3 provides the details of MRI's observation of an actual lining installation at a site in Oklahoma. Section 4 provides supplemental observational information from a site in Colorado and data from an installation in California. Section 5 contains our conclusions regarding the IECC lining process. MR1-AwrwM4W-FR