COMPLIANCE INFO_2020 - Laserfiche WebLink

Home Browse Search

Spill Prevention Control and Countermeasure Plan Food Express, Inc. 1250 Madruga Road FOOD EXPRESS, INC. Lathrop, California 95330 May 2020 Page 20 13.4.2. CORROSION PROTECTION OF PARTIALLY BURIED METALLIC CONTAINERS [40 CFR§112.8(C)(5)]: Not applicable since there are no partially buried metallic storage containers at this facility. 13.5. CERTIFIED INSPECTION &TESTING OF STORAGE CONTAINERS FOR INTEGRITY [40 CFR§112.8(C)(6)]: A major objective of the SPCC regulations is the prevention of oil leaks. The original SPCC regulations required all containers be subjected to regular visual inspections and another form of non-destructive testing (i.e. point in time liquid-tightness testing) to demonstrate the containers had integrity. The regulations also made provisions for the proposal of alternative programs of visual inspections and integrity testing as long as it was proposed by a certified Professional Engineer (P.E.) and could achieve environmental equivalence as the regimen presented in the original regulations. The environmental equivalence standard required the regimen to be judged congruent with 1.) Good engineering practices and 2.) Industry standards. In 2004, the USEPA retreated from their position by specifying regular visual observation alone met the environmental equivalence standard for containers less than 30,000 gallons'. This was partly due to the Steel Tank Institute's (STI's) development of a risk-based inspection standard known as SP001. Early versions of SP001 declared that for containers less than 30,000 gallons capacity, visual inspections alone were sufficient to detect possible releases and no additional testing was necessary. The SP001 standard further defined risk by identifying three categories of risk: • Category 1 - Low • Category 2 - Moderate • Category 3 - High Containers are judged to achieve the Category 1 position when employing 1) A "spill control" mechanism, and 2) A "continuous release detection method" (CRDM) in place. Since all of the containers at the facility employ both elements they are therefore are classified as Category 1 or Low Risk. The USEPA accepted regular visual inspections for Category 1 containers with shell capacity of less than 30,000 gallons but insisted the containers also met the following criteria: • Well-designed, • Shop-built, • Elevated to allow visual inspection or placed on an impervious barrier. 6 The USEPA was challenged legally by the Petroleum Marketers Association of America(PMAA). This challenge resulted in a legal agreement with the findings published in the USEPA's 2005 edition of"SPCC Guidance for Regional Inspectors", dated March 29, 2004. =ATC Page 20