Spill Prevention Control and Countermeasure (SPCC) Plans can be complex and unclear at times, particularly around aboveground storage tank (AST) inspection requirements. The intent of AST inspection requirements is to detect oil leaks, spills, or other potential integrity or structural issues before resulting in a discharge of oil to navigable waters of the U.S. or adjoining shorelines. Does your facility have an SPCC Plan? If so, how do the requirements apply? Let’s take a look.
How does the SPCC Rule define ASTs?
Interestingly, the U.S. Environmental Protection Agency (EPA) 40 does not specifically use the term AST in CFR 112 (the SPCC rule), but rather includes and describes ASTs under the definition of bulk storage container[1]. A bulk storage container is defined in §112.2 as “:
“…any container used to store oil. These containers are used for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce. Oil-filled electrical, operating, or manufacturing equipment (flow through process vessels and transformers) are not bulk storage containers.”
What are SPCC inspection requirements for ASTs?
All facilities that have oil storage greater than or equal to 1,320 gallons are subject to the requirements outlined in §112.7 (General Requirements for Spill Prevention, Control, and Countermeasures Plans). From there, the SPCC rule has several varying components depending on your facility’s design and industry. Facility- and industry-specific sections include:
- 112.8 Most onshore facilities (excluding production facilities – oil and gas production well sites).
- 112.9 Onshore oil production facilities (excluding drilling and workover facilities).
- 112.10 Onshore drilling workover facilities.
- 112.11 Offshore drilling activities.
- 112.12 Animal and plant-based oils and greases.
Inspection requirements differ based on the specific industry, location, or design, so it’s important to understand the requirements outlined in each section.
Since a vast majority of SPCC plans are written for Onshore Facilities (§112.8), let’s focus on Onshore Facilities, which are outlined in §112.8, paragraph (6). The SPCC rule indicates that each aboveground container (AST) must be tested or inspected for integrity on a regular schedule and whenever material repairs are made. As the plan holder, it is up to you and the certifying Professional Engineer (PE) to determine, in accordance with good engineering practices/industry standards (typically API 653 or STI SP001, which consider container size, configuration, and design[2]), the appropriate qualifications (State) for personnel performing tests and inspections, the frequency and type of testing, and inspections. Each engineering practice has specific points of interest that you must inspect and keep records for. Records of visual inspections and formal tests have separate retention requirements. It is important to understand and maintain each inspection per the requirement of your facility.
What is the AST inspection procedure described in the SPCC Rule?
The SPCC rule does not specify which type of inspections to do or when to do it. The type of inspection program and its scope will depend on site-specific conditions and the application of good engineering practices. The goal of the language here is for your facility to inspect each AST to one or a combination of the two applicable industry standards or design your own with the PE and describe your standard in great detail. This is very rare, but it’s important to understand that the SPCC regulation allows for modification if the engineer and facility agree, and the designed standard meets all components of the regulation. For most instances, the American Petroleum Institute (API) Standard 653 (API 653) “Tank Inspection, Repair, Alteration, and Reconstruction” and the Steel Tank Institute (STI) “SP001 Standard for the Inspection of Aboveground Storage Tanks” (STI SP001) are two commonly used inspection standards for aboveground bulk storage. Once the standard is clearly identified and discussed in your plan, you should design an inspection program in alignment with both compliance and engineering practices. For our discussion, we will stick with the two most common standards out there today.
Background on API and STI Standards
API 653 covers steel storage tanks built to design specifications in API-650 and its predecessor API 12. It provides minimum requirements for maintaining the integrity of tanks after they have been placed in service and addresses inspection, repair, alteration, relocation, and reconstruction. This standard is typically used to establish an integrity testing program for field-erected tanks, primarily for ASTs that are 23,000 US gallons (15 feet in diameter and 18 feet tall) and larger that are designed using API 650.
STI SP-001 focuses primarily on the inspection of welded, carbon steel, shop-fabricated, and small field-erected tanks, 75,000 US gallons or smaller (30 feet in diameter, 50 feet tall). Also included is the inspection of smaller, portable containers such as 55-gallon drums, intermediate bulk containers (IBCs), and other such containers that may be of metal or plastic construction.
Do you have to use API or STI standards to develop your inspection schedule?
That’s a Yes and No answer. The SPCC rule allows flexibility for a PE to develop a hybrid and/or environmentally equivalent program that follows one or both of the established standards; however, with any deviation from a recognized and published standard, the PE and company take on an extra level of liability, and the plan must clearly explain how, what, when, and why your facility is designing its own practice for ensuring compliance with the rule.
As an inspector, one must recognize and fully understand the facility’s inspection program per the facility’s SPCC plan. For example, are there any state-specific certification requirements to perform periodic inspections? What are the prescribed timeframes in the facility’s plan stating these inspections are to be completed? Remember, the PE must review and approve any alternative inspection standard.
What does EPA look for in an inspection schedule?
When it comes to an inspection schedule, what does EPA look for? This is one of the main questions we get asked by our clients. The main document all EPA inspectors use is the SPCC Guidance for Regional Inspectors[3].
All EPA inspectors are trained to use and follow the SPCC Guidance for Regional Inspectors1. This manual provides step-by-step guidance for EPA regional inspectors to conduct their inspections.
The guidance manual also includes detailed explanations of compliance with the SPCC rule if any findings are discussed during the inspection. Become familiar with Chapter 7: Inspections, Evaluation, and Testing. Key topics addressed in this chapter include:
- A clear facility overview of the SPCC inspection, evaluation, and testing requirements, as well as how environmental equivalence may apply to these requirements.
- Measures on how the EPA inspector will determine a facility’s compliance with the inspection, evaluation, and testing rule requirements.
- Details surrounding how the inspector identifies findings with industry standards, federal code requirements, and recommended practices that apply to different types of equipment.
Remember this is a federal inspection and not a local or state inspection, which may have additional requirements your facility must adhere to.
Wrapping It Up
Many companies have or should have this document in their compliance library. Time and time again, it is not until an inspector shows up at your doorstep that compliance starts to happen. These regulations are meant to be a proactive approach to spill prevention and financial loss. Reducing risk is a key aspect of an SPCC plan to ensure you are complying with the minimum requirements identified under §112.8, paragraph (6).
To learn more, please contact Amy Bauer or James Dodd.
[1] https://www.epa.gov/ust/aboveground-storage-tanks
[2] Examples of these integrity tests include, but are not limited to visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other systems of non-destructive testing.
[3] https://www.epa.gov/sites/default/files/2014-04/documents/spcc_guidance_fulltext_2014.pdf
