From: Hans Schmoldt, Corrosion Engineer & Cathodic Protection Specialist
To: SPCC Plan Administrators
Subject: Anode Systems' Produced Water Tank Corrosion Prevention Program
Dear Administrator:
In January of this year a new SPCC rule became effective. The
amended SPCC regulations no longer exempt produced water tanks at
oil
production facilities.
This engineer interprets the new regulation to include gas production
facilities
if they produce an oil or gas liquid as a by product of natural gas
production.
If you believe, as I do, that the intent of the new rule is to prevent
spills
from produced water tanks caused by corrosion, take time to read on.
Attached
are “talking points” on the subject of corrosion of produced water tanks,
the
costs to the oil and gas industry from corrosion, the benefits of cathodic
protection of oil and gas production facilities, milestones in the evolution
of
the EPA
rules that govern the oil and gas industry and facts worth noting.
Leaking tanks are nothing new. What is new, is the recognition by the EPA
that
leaking tanks pose a problem to public health and the environment. Allowing
oily
salt water to spill into the ground or into ground water through holes in a
tank's bottom is not allowed any more. Furthermore, it's not good business
nor
is it a responsible business practice.
For years, corrosion has been controlled and stopped with anodes in a
process
called cathodic protection. Anodes are used in heater treaters, heat
exchangers,
water tanks, water condensers, water trucks, petroleum products tanks and in
domestic water heater tanks. Anodes are required by Federal law on
underground
or on grade steel fuel storage tanks. Anodes are required by Federal law on
oil
and gas transmission and distribution pipelines. The fact is, cathodic
protection has been proven to stop corrosion of steel tanks and pipes.
Anode Systems has been making and installing anodes for the gas industry for
25
years. Anode Systems can design and install anodes inside or outside your
produced water tanks. We will inspect, test and maintain test records of the
cathodic protection and we will make the repairs to a cathodic protection
system
for your tanks and associated piping as required by the SPCC regulations.
Call or e-mail us for a cost estimate to bring your facilities up to code
and
more importantly, to protect your investment in your produced water
facilities.
We are NACE certified and have the experience necessary to design, install,
maintain, repair and upgrade any cathodic protection you have or need.
Yours truly, Hans Schmoldt NACE Cathodic Protection Specialist #4162
