SPCC Baseline Tank Inspection Deadline--11-10--2016

SPCC Baseline Tank Inspection Deadline--November 10, 2016

EPA updated the SPCC regulation in 2002, but certain provisions, including tank inspection were delayed. EPA allowed 5 years for SPCC plan renewals and 5 years for the work to get done. We are nearly there.

Daily Inspection--Example

The SCPP regulation specifies that inventory be taken daily and that equipment be inspected "frequently."



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Tank Operations
40CFR 122.8.c.6

"... In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph...."

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Most SPCC plan writers interpret the inspection requirement as daily for facilities that are manned on a regular basis, and set some other frequency, typically weekly or monthly, for unmanned locations. This can be integrated into daily inventory documentation, inventory reconciliation, and solids/water monitoring.