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SPCC Requirements for Inspections, Evaluations and Testing – Part I
The SPCC requirements for inspections, evaluations and testing are intended to help facility owners and operators prevent oil spills by keeping close tabs on the safety and integrity of containers, piping, valves, appurtenances, and factors such as secondary containment. The requirements span several sections of the regulation and consider many aspects including the type of industry, as well as facility and equipment location (i.e., onshore or offshore, above ground or underground), capacity and structural condition.
Despite these different regulatory divisions, there are several rule that apply to all covered facilities, across all industries and locations. These requirements are contained in 40 CFR 112.7, General requirements for Spill Prevention, Control and Countermeasure Plans, and include:
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112.7(d) Bulk storage containers with no secondary containment and for which an impracticability determination has been made.
Requirement: Periodic integrity testing for all bulk storage containers (including those at oil production, drilling and workover facilities that are not typically subject to integrity testing requirements). In cases where secondary containment is determined to be impracticable, good engineering practices may suggest more frequent testing than would otherwise be required.
112.7(d) Valves and piping associated with bulk storage containers with no secondary containment and for which an impracticability determination has been made.
Requirement: Periodic integrity and leak testing as defined in 112.7(c).
112.7(e) Recordkeeping.
Requirements: For all actions, maintain written inspection and testing procedures and a signed record of all inspections and tests (including required evaluations such as for brittle fracture) conducted for three years, according to usual and customary business practices. EPA notes that certain other industry also standards require recordkeeping beyond three years and recommends that records and reports from formal testing and inspections be retained for the life of the container.
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112.7(h)(3) Lowermost drain and outlets of tank car or tank truck at loading/unloading racks.
Requirement: Perform a visual inspection prior to filling and departure of a tank car or a tank truck from loading/unloading racks.
112.7(i) Field-constructed aboveground container.
Requirements: When such a container undergoes a repair, alteration, reconstruction, or a change in service that could affect the subsequent risk of a discharge or failure from brittle fracture or other catastrophic event, or has discharged oil or failed due to brittle fracture or other catastrophic failure, conduct and evaluation for the potential for brittle fracture or other catastrophic failure of the container. Appropriate corrective action must be taken based on the results of the brittle fracture evaluation.
When considering compliance with these general requirements, facility owners and operators should keep in mind that the SPCC rule is performance based, and as a result, the EPA does not prescribe specific frequencies or methods for inspections, evaluations and testing. Instead, compliance decisions should incorporate the use of good engineering practices, as well as other recommended practices, safety considerations, applicable requirements contained in other federal, state and local regulations, and sound industry practices. EPA also maintains that continued research and development into new technologies as well as ongoing industry standard development and implementation should also be taken into consideration when creating SPCC plans.