COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

Po 12e2 The last API 653 COS Inspection for Tank 7 was conducted by E&M Tank Program for BP US Pipelines & Logistics. After purchasing the terminal from BP, Buckeye's Tank Integrity Department completed a review of all tanks and determined Tank 7 could be reclassified and inspected under the STI SP001-01 standard. Since Tank 7 is on a concrete pad and has full secondary containment, the STI standard requires the tank have an external inspection in 20 years and no internal inspection is required. Buckeye has scheduled the next STI tank inspection to be completed in 2029. The Buckeye Terminal Maintenance and Inspection Program, BEST, as well as the SPCC plan, will both reflect STI standards for the 2029 inspection of Tank 7. Inspections will be performed by a qualified STI inspector. Because of the tank size and it being in full secondary containment, the 400-gallon generator diesel tank does not require external or internal inspection under the STI SP001. Copies of the monthly inspections are maintained onsite and uploaded to BEST. Remark: Each aboveground container shall be tested and inspected for integrity on a regular schedule and whenever repairs are made. The qualifications of personnel performing tests and inspections,frequency and type of testing and inspections that take into account container size, configuration, and design shall be determined in accordance with industry standards. 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. Comparison records and other records of inspections and test must be maintained on site. Response: Buckeye does not agree with this violation or remark. According to 40 CFR 112.8(c)(6), the frequency and type of testing and inspections as well as the qualifications for personnel performing tests and inspections must be determined in accordance with applicable industry standards. While frequent external visual inspections can often be completed by trained facility personnel, the requirement to conduct regular integrity tests or inspections may involve hiring specialized personnel(as specified by the applicable industry standard). Buckeye meets this requirement to conduct regular integrity tests or inspections by using certified and qualified API 653 or STI SP001-01 contractors. The SPCC rules require frequent inspections of the outside of container for signs of deterioration, discharges, or accumulation of oil inside diked areas. This visual inspection is intended to be a routine walk-around and includes the container's supports and foundations. Buckeye meets this requirement by conducting monthly inspection of the tanks using trained Buckeye Terminal Operators. The SPCC rules require that records of inspections and tests be kept under usual and customary business practices. The Buckeye Terminal Maintenance and Inspection Program is maintained and managed by Buckeye's Tank Integrity Department using the BEST database. All Operators at the Stockton Terminal have access to BEST; which is also used to store all monthly/annual tank inspections along with API 653 and STI SP001-01 reports, data and records. All information contained within BEST can be viewed and printed locally as needed.. This provides real time data that is easily and readily accessible to all applicable employees and is part of Buckeye's waste minimization and sustainability program.