SPCC Inspection, Evaluation, and Testing—5 General Things Inspectors Are Looking For
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1) A complete SPCC Plan that contains a description of “the scope and schedule of inspection, evaluation, and testing to be performed on bulk containers.” In its SPCC Guidance for Regional Inspectors, the EPA references the following sections of 40 CFR 112 that address specific requirements at all or certain facilities:
- 112.3(d)(1)(iv)—requires that procedures for required inspections and testing have been establishedfor all covered facilities;
- 112.7(e)—defines general requirements for inspections, tests, and recordkeeping for all covered facilities;
- 112.8(c)(6)—defines tank integrity testing and inspection requirements for onshore facilities (excluding production facilities);
- 112.9(c)(3)—defines visual inspection requirements for onshore oil production facilities (excluding drilling and workover facilities); and
- 112.12(c)(6)—defines tank integrity testing and inspection requirements for facilities that store animal fats and oils and greases, fish and marine mammal oils, and vegetable oils, including oils from seeds, nuts, fruits, and kernels (AFVO).
Tank owners should also reference any applicable industry inspection standards used in their SPCC plans.
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2) A complete description of equivalent programs developed by a professional engineer (PE), such as a hybrid inspection program. Inspectors will need to verify the following:
- That the program is being implemented at the facility;
- That a clear rationale is provided for the environmental equivalency, including how it deviates from applicable industry standards or that no industry standards exist;
- That the equivalent program meets the minimum requirements for a hybrid program provided in Section 112.7(a)(2);
- That the scheduling of integrity testing is such that it ensures implementation of any schedule associated with Section 112.7;
- That the rationale is provided for any inspection schedule that extends beyond the frequency identified in applicable inspection standards (particularly if no baseline exists for the tanks); and
- That the program has been developed by a PE in accordance with good engineering practice.
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3) Records of visual inspections and integrity testing as defined in Section 112.7(e):
“You must keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of 3 years. Records of inspections and tests kept under usual and customary business practices will suffice for purposes of this paragraph.”
Inspectors will want to see that the written procedures and records are signed by the appropriate supervisor or inspector and maintained for a period of 3 years (or 5 years for Facility Response Plan (FRP) holders). Industry standards may advise that records of certified inspections and non-destructive testing be retained for the life of the container.
4) Checklists used are in accordance with the certified SPCC Plan. The SPCC rule provides for the use of industry standards, which may include checklists for different inspection and testing activities. The inspector will want to compare the checklists that are actually used with those described in the facility’s SPCC Plan. Examples of tank inspection checklists can be found in industry standards such as STI SP001 from the Steel Tank Institute, as well as in Appendix F of 40 CFR 112 (note that while this appendix deals with FRPs, the checklist can be used for SPCC plans as well).
5) Recommended or required actions resulting from inspections and tests are completed and documented. For example, if the tank integrity evaluation/testing report recommends and/or requires repairs necessary to prevent a discharge, the inspector will need to see documentation confirming that the repair was completed or describes the rationale for why the repair was not performed.