Special Topics in Environmental Management

SPCC Inspection, Evaluation, and Testing—5 Specific Things Inspectors Are Looking For

SPCC Inspection, Evaluation, and Testing—5 Specific Things Inspectors Are Looking For

1) Regular leak testing of tanks that are completely buried. Any completely buried tank that was installed on or after January 10, 1974, must be leak tested regularly “in accordance with industry standards or at a frequency sufficient to prevent leaks.” While there are a variety of appropriate methods for leak testing such underground storage tanks (USTs), the chosen method should be based on good engineering practices and tests conducted in accordance with 40 CFR 280.43 or an approved state program. EPA inspectors will want to review the SPCC Plan to ensure it contains a description of the chosen method and the schedule for leak testing.

2) Periodic integrity testing of the tank and periodic integrity and leak testing of the valves and piping at on-shore oil production facilities with bulk storage tanks for which secondary containment is determined to be impracticable. Inspectors will review the SPCC Plan to ensure it follows the provision of Section 112.7(d) and includes a clear explanation of why the secondary containment is not practicable. Facilities that have not submitted a Facility Response Plan (FRP) may also be required to include the following in their SPCC Plan:

  • An oil spill contingency plan following the provisions of 40 CFR 109, and
  • A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful.

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3) Piping installed or replaced after August 16, 2002 at onshore facilities (other than oil production facilities) must be protectively wrapped and coated, cathodically protected, and regularly inspected according to 112.8(d)(4). Buried pipeline that becomes exposed for any reason must also be inspected for corrosion. In both cases, corrective action must be taken when corrosion is found. Inspectors will want to review records of inspections and subsequent corrective actions taken, if any were necessary.

4) Specific requirements must be met for onshore oil production facilities opting to implement the alternative to sized secondary containment for flow-through process vessels. Inspectors will want to ensure three requirements are met:

  • Periodically and on a regular schedule visually inspect and/or test flow-through process vessels and associated components (such as dump valves) for leaks, corrosion, or other conditions that could lead to a discharge, as described in Section 112.1(b);
  • Take corrective action or make repairs to flow-through process vessels and any associated components as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge; and
  • Promptly remove or initiate actions to stabilize and remediate any accumulations of oil discharges associated with flow-through process vessels.

Facilities that discharge more than 1,000 gallons of oil in a single discharge or more than 42 gallons of oil in each of two discharges within any 12-month period from flow-through process vessels (excluding discharges resulting from natural disasters, acts of war, or terrorism) must, within 6 months, ensure that all flow-through process vessels subject to Section 112.9(c)(5) comply with Sections 112.9(c)(2) and (c)(3) for sized secondary containment.

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5) When an oil tank’s capacity is altered and rerated, the SPCC Plan (and the FRP if required) must be reassessed and altered accordingly. Inspectors will carefully review the SPCC Plan to determine if the tank alterations are appropriately addressed including, but not limited to:

  • Relevant SPCC requirements and documentation such as PE certification of the technical amendment and operating procedure updates;
  • Relevant industry standards (i.e., API 650 and API 653 specifications), including conformance documentation; and
  • Records required by industry standards and documentation of overflow port sizing, modifications made, overflow inspection, materials, welding procedures, examinations, and testing methods.

Inspectors conducting field observations of rerated tanks will pay particular attention to overflow port location, shell plate thickness and spacing, and overflow nozzles and overflow pipe support, sizing, and placement.