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Regularly scheduled inspections, evaluations, and testing of bulk oil storage containers and loading and unloading areas by qualified personnel are critical parts of discharge prevention.
You must conduct integrity testing and routinely inspect, as defined in your SPCC Plan, the following aboveground bulk oil storage containers with a capacity of 55 gallons or more:
- Large field-constructed or field-erected containers and small shop-built bulk storage containers;
- Stationary tanks and portable tanks;
- Containers located on the ground, off the ground, and partially in the ground, including partially buried, bunkered, or vaulted tanks; and
- Double-walled containers on underground tanks.
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Did you know? Oil-filled equipment is not a bulk storage container and, therefore, is not subject to the integrity testing requirements of the SPCC rule.
The SPCC rule on inspections and testing requires that you:
- Frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. This visual inspection is intended to be a routine walkaround and must include the container’s supports and foundations.
- Perform periodic formal inspections of oil tanks conducted by a certified inspector.
- Test or inspect each container for integrity on a regular schedule and whenever you make material repairs.
- Identify in your SPCC Plan the type and frequency of testing and inspection for each container and the appropriate qualifications of personnel performing the tests and inspections. You should also include in the Plan the type of integrity inspection that will be conducted and the inspection schedule planned for containers that have not yet been inspected.
Tank Testing and Inspection Plan
According to the SPCC rule, a testing and inspection plan must be developed for aboveground bulk storage oil containers.
- Your organization or a registered professional engineer must determine which industry standards are applicable. The industry standard identified will outline the specific inspection and testing protocol for the containers at your facility.
- These protocols may vary depending on the size and configuration of containers. For example, portable containers, like drums, have fewer inspection requirements than shop-built and field-erected containers.
- If you have containers that have never been inspected for integrity, depending on their size and configuration, industry standards may require that you assess baseline conditions for these containers.
- You must also determine, in accordance with the industry standards, the appropriate qualifications for personnel performing tests and inspections.
- And, you must determine the frequency and type of testing and inspections. This must take into account the aboveground container size, configuration, and design, for example, shop-built, field-erected, skid-mounted, elevated, equipped with a liner, double-walled, or partially buried.
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How Often Do You Have to Inspect?
The rules require testing and inspection on a regular schedule. This means testing and inspections according to industry standards or at a frequency sufficient to prevent discharges.
- You must test or inspect each aboveground container for integrity on a regular schedule.
- You must also test or inspect whenever you make material repairs.
- Industry standards establish the scope and frequency for inspections considering the particular condition of the aboveground container. These conditions may include the age, service history, original construction specifications, prior inspection results, and the existing condition of the container. They may also consider the degree of risk of a discharge to navigable waters or adjoining shorelines, for example, containers located near saltwater, where an accelerated corrosion rate would be expected.
See tomorrow’s Advisor for tips on how to properly inspect oil tanks for SPCC.