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Bulk Storage Container Inspection Fact Sheet July 2012 How do I establish a baseline condition for my aboveground container? Industry standards, such as API 653 and STI SP001, contain minimum requirements to inspect aboveground containers and criteria to assess each container's suitability for continued service. The baseline and suitability evaluation provides information on the container's existing condition relative to the design metal thickness and the rate of metal loss from corrosion as well as the anticipated remaining service. In some cases, where baseline information is not known,the testing program may include two data collection periods, one to establish a baseline of the container's existing shell and bottom plate thicknesses, and a second inspection to establish corrosion rates in order to develop the next inspection interval. These inspection intervals establish the frequency of the `regular schedule' required for testing under the SPCC rule. When no or only partial baseline information is available for a containers)at the facility, then the owner/operator needs to schedule integrity testing as soon as possible. One time frame you may consider is that the SPCC Plan be reviewed at the facility every five years. As an example, when no or only partial baseline information is available for a container, the Plan preparer should schedule integrity testing within the first five-year review cycle of the SPCC Plan to establish a regular testing schedule based on current container conditions and the applicable industry standard. For this example, the review cycle would begin on the revised rule implementation compliance date of November 10, 2011 and the first(baseline)container inspection or integrity test would be completed by November 10, 2016. The implementation of the testing program should be in accordance with industry standards and establish appropriate inspection priorities among multiple containers at a facility. For instance, special consideration may be discussed in the Plan for containers for which the age and existing condition is not known (no baseline or only partial information exists); older containers; or those in more demanding service. These higher priority containers may be targeted for inspection in the schedule before other aboveground containers where the baseline information is known. Section 112.7 of the rule states that if the Plan calls for additional facilities or procedures, methods, or equipment not yet fully operational, you must discuss these items in separate paragraphs, and must explain separately the details of installation and operational start-up.Therefore, if an owner or operator has yet to implement the integrity testing program,the SPCC Plan should establish and document a schedule (in accordance with good engineering practice and the introductory paragraph of 112.7)that describes the projected implementation of the integrity testing program for the aboveground bulk storage containers at the facility. The owner or operator must then implement the inspection program in accordance with the SPCC Plan. Do I need to establish a baseline when the standard requires only visual inspections? No, if the industry standard only requires visual inspections for the container(e.g., certain shop-built containers)then a baseline is not necessary. The standard establishes a frequency for visual inspections rather than basing the interval on the containers corrosion rate. On the other hand, a baseline is necessary for most non-destructive testing protocols, because the container's corrosion rate impacts the frequency/interval of future formal integrity testing inspections. Owners and operators need to refer to the particular industry standard identified in the SPCC Plan to determine the scope of inspection and testing requirements. For example under the STI SP001 standard, visual inspection is allowed for portable containers such as drums and totes. A baseline determination of metal thickness of a portable container is not required prior to implementing the visual only integrity testing inspection protocol. How do I demonstrate in my SPCC Plan that I have an inspection and/or testing program for containers that I have not yet inspected? The introductory paragraph of§112.7 of the SPCC rule allows for the owner or operator to describe procedures, methods, or equipment that are not yet operational in the SPCC Plan and in this event, requires the owner or operator to include a discussion of the details. Office of Emergency Management 4