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.

SPCC and Tank Inspections: FAQ




The Regulation
40 CFR 112.8.c
(6) Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep comparison records and you must also inspect the container's supports and foundations. 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 recordkeeping requirements of this paragraph.


Question:
What codes can we inspect to? I understand there are several—API 653, API 575, STI SP001-00, API RP 12R1—is one cheaper, or better, or simpler?

Answer:
Yes, all of these are acceptable (See table 7.1 SPCC Guidance for Regional Inspectors). API 575 and STI 001 tend to be less expensive because they simpler and require less documentation. API 653 includes reconstruction and extensive modifications, adding complexity to the inspection process. API 575 is also more flexible, as it is not tied to one specific tank design family.


Question:
I have less than 10,000 gallons total oil storage and my plan is self-certifying. Do I still need to use a certified inspector?

Answer:
Yes. All tanks >500 gallons require inspection. Tanks under 5,000 gallon do not require a certified inspection if they are elevated above the ground, typically a horizontal tank on saddles.


Question:
How many tanks are out there?

Answer:
EPA estimates there are now 571,000 SPCC facilities. There are 3,500 API inspectors and 350 STI inspectors, so it is east to imagine that things are going to get busy. More than half of these are less than 10,000 gallons and about 70% are estimated to be uninspected.

Question:
I don’t have to test hydraulic reservoirs and other pieces of oil filled equipment, only tanks, right?

Answer:
Actually, they must be inspected if they meet the size requirements. In the old SPCC rule they were not "tanks," but now they are.


Question:
What if the inspections turn up deficiencies that are not a part of the SPCC requirements? I understand that the inspection codes are strict and sometimes go beyond what is required?

Answer:
The EPA is well aware of this conflict, and they are not requiring that factors not directly relating to tank integrity be reported. However, other non-compliance issues (fire code, building code, air pollution) are important and are the responsibility of the tank owner. They have discussed this subject at length in this document: http://www.epa.gov/oem/docs/oil/fss/fss06/fahnline_2.pdf.  Additionally, the PE certifying your SPCC plan can include all of these factors, because many do have some bearing on the safety of the tank installation. We will inspect your tanks according to the language in your SPCC plan.

Some states require testing to specific codes. In these states we will follow the inspection code as written.


Question:
Are the rules the same in all states?

Answer:
Rules vary. Delaware has required API testing of field erected large tanks for some time. Florida requires 3rd party API testing of field erected tanks. Virginia requires testing of tanks at facilities subject to ODCP  requirements (generally tanks over 20,000 gallons) and has some additional requirements. Other states have no specific rules. However, all states require meeting the SPCC inspection requirements.

Question:
My tanks have waste animal fats, not petroleum. I’m exempt, right?

Answer:
No. Although fats contained in tanks subject to FDA requirements enjoy certain exemptions because of inspection requirements in those rules, waste fat tanks are subject to certified inspection.
Subpart C—Requirements for Animal Fats and Oils and Greases, and Fish and Marine Mammal Oils; and for Vegetable Oils, including Oils from Seeds, Nuts, Fruits, and Kernels.

112.12 (6) Bulk storage container inspections.
(i) Except for containers that meet the criteria provided in paragraph (c)(6)(ii) of this section, test or inspect each above ground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration, and design (such as containers that are: shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried). Examples of these integrity tests include, but are not limited to: Visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing. You must keep comparison records and you must also inspect the container's supports and foundations. 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.
(ii) For bulk storage containers that are subject to 21 CFR part 110, are elevated, constructed of austenitic stainless steel, have no external insulation, and are shop-fabricated, conduct formal visual inspection on a regular schedule. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. You must determine and document in the Plan the appropriate qualifications for personnel performing tests and inspections. Records of inspections and tests kept under usual and customary business practices satisfy the record keeping requirements of this paragraph (c)(6).

Question:
Oil field production tanks are exempt, right?

Answer:
Yes and No. Because production tanks are generally in the field for a limited time, they are sometimes exempt from internal inspections and thickness testing. However, visual inspections and documentation are required, though the inspector does not need to be industry certified. Internal inspections and thickness testing are required at the time of installation, if the tank has been moved from another location.


Question:
Are there any limits to the sizes of tanks we will inspect?

Answer:
Inspectors are not limited; they can inspect any tank. As a general rule, as a small company I specialize in tanks not exceeding 100,000 gallons. However, I will work with you on larger tanks.


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For more details see the following: