Special Topics in Environmental Management

SPCC: Tips for Tank Inspections

The following Table outlines the inspection requirements for tanks and associated piping at onshore nonproduction facilities that store petroleum and nonpetroleum oils—except animal fats and vegetable oils, which have their own set of inspection requirements. Note: The SPCC rule also contains integrity testing provisions for tanks, which are not included in this table.  In addition, there are inspection, evaluation, and testing requirements for other equipment, such as drains and outlets of tank trucks at loading/unloading racks.

Table: Inspection Requirements for Tanks at Onshore Nonproduction Facilities

Component Requirement Frequency
Field-constructed aboveground container Evaluate potential for brittle fracture or other catastrophic failure. When the container undergoes a repair, alteration, reconstruction, or a change in service; or has discharged oil or failed
Diked areas for bulk storage containers Inspect retained rainwater to ensure that it will not cause a discharge when draining to storm sewer or open watercourse, lake, or pond. Prior to draining
Aboveground bulk storage container Test or inspect each container for integrity. Following a regular schedule and whenever material repairs are made
Aboveground bulk storage container Inspect outside of container for signs of deterioration and discharges. Frequently
Aboveground bulk storage container supports and foundations Inspect container’s supports and foundations. Following a regular schedule and whenever material repairs are made
Diked areas around bulk containers Inspect for signs of deterioration, discharges, or accumulation of oil inside diked areas. Frequently
Steam return and exhaust lines Monitor for leaks from defective internal heating coils. On an ongoing or regular basis
Buried piping (except buried piping connected to an exempt completely buried storage tank) Inspect for deterioration. Whenever a section of buried line is exposed for any reason
All aboveground valves, piping, and appurtenances During the inspection, assess general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. Regularly

 


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SPCC regulations require that inspection records be kept for 3 years. However, the EPA recommends that all testing and inspection records be kept for the life of the container.

What does ‘frequently’ mean?

The SPCC rule requires frequent inspections of the outside of the tank for signs of deterioration, discharges, or accumulations of oil inside diked areas. According to the EPA, this visual inspection is intended to be a routine walk-around and includes the tank’s supports and foundations. The scope and frequency of the inspection is determined by industry standards or according to a site-specific inspection program developed and certified by the SPCC Plan preparer. Industry standards typically require monthly visual inspections, although some facilities conduct daily or weekly visual inspections of their containers. Visual inspection should occur on an ongoing routine basis, be conducted by qualified personnel, and follow industry standards.

What about a ‘hybrid’ inspection program?

You can use a site-specific “hybrid” inspection program if in the judgment of the professional engineer (PE) or qualified facility owner/operator, no industry standard applies to a particular tank.


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This is a partial list of items to consider regarding the elements of a hybrid inspection program.

For shop-built tanks:

  • Visually inspect exterior of tank;
  • Evaluate external pitting;
  • Evaluate hoop stress and longitudinal stress risks where corrosion of the shell is present;
  • Evaluate condition and operation of appurtenances;
  • Evaluate welds;
  • Establish corrosion rates and determine the inspection interval and suitability for continued service;
  • Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided;
  • Evaluate the structural integrity of the foundation;
  • Evaluate anchor bolts in areas where required; and
  • Evaluate the tank to determine that it is hydraulically sound and not leaking.

For field-erected tanks:

  • Evaluate foundation;
  • Evaluate settlement;
  • Determine safe product fill height;
  • Determine shell corrosion rate and remaining life;
  • Determine bottom corrosion rate and remaining life;
  • Determine the inspection interval and suitability for continued service;
  • Evaluate welds;
  • Evaluate coatings and linings;
  • Evaluate repairs for risk of brittle fracture; and
  • Evaluate the tank to determine that it is hydraulically sound and not leaking.