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Bulk Storage Container Inspection Fact Sheet July 2012 The Plan preparer must provide details in the Plan including a timeline to gather the necessary baseline data to establish a regular schedule of integrity testing in accordance with §§112.8(c)(6)and 112.12(c)(6).The Plan preparer may need to consult with a tank professional and/or PE to determine the scope of the integrity testing program for the containers. Include in your Plan a description of the inspection program including: • The type of integrity inspection that will be conducted (i.e., visual or another non-destructive method), • The applicable industry standard that the serves as the basis for program • The implementation schedule for inspecting containers, and • Any other considerations that went into the development of the inspection program. Ensure that your containers fall within the scope of the industry inspection standard that you elect to follow and include a description of the inspection procedures in the SPCC Plan. Finally, include information on recordkeeping procedures in the Plan. What are my recordkeeping requirements? The facility integrity testing and inspection program must be documented in the Plan, including the schedule for conducting inspections and tests. The SPCC rule requires that you keep a record of the inspections and tests, signed by the appropriate supervisor or inspector, for a period of three years. However, industry standards often advise that records for formal inspections and tests be maintained for the life of the container. EPA strongly recommends that you keep comparison records of integrity inspections and tests as directed in the standard, but no less than three years in accordance with the SPCC record retention requirement, in order to identify changing conditions of the oil storage container. Records of inspections and tests kept under usual and customary business practices satisfy the recordkeeping requirements. Can I visually inspect large shop-built oil storage containers to satisfy the integrity inspection and testing requirements of the SPCC rule? Yes, under certain circumstances visual inspection alone may suffice. However, the SPCC rule requires that inspections be in accordance with industry standards. For tanks larger than 5,000 gallons, most industry standards require more than a visual inspection by the owner or operator. The SPCC Guidance for Regional Inspectors' published in 2005 describes an example that may be environmentally equivalent to the integrity testing requirements of the SPCC rule at that time.The example indicates that visual inspection plus certain additional actions to ensure the containment and detection of leaks may be appropriate for bulk oil storage containers with a capacity up to 30,000 gallons. This example is based on a policy that described the environmental equivalence flexibility available to a PE with respect to integrity testing in a letter to the Petroleum Marketers Association of America (PMAA).'This policy was established at a time when the rule specifically required that integrity testing include more than just a visual inspection. While the policy and approach for the use of environmental equivalence described in this letter is still valid, EPA revised the integrity testing provision in 2008 to allow inspection requirements outlined in industry standards to be used without the need for environmental equivalence determinations certified by a PE. A major industry standard for integrity testing (STI SP001)was modified since the letter to PMAA was written to outline "good engineering practice"for integrity testing of shop-built containers. This may affect a PE's decision whether to certify an environmentally equivalent approach as described in the PMAA letter, or to follow an industry standard.3 If an owner or operator wants to deviate from applicable industry standards to develop an integrity testing program,then a PE must certify an environmentally equivalent alternative in the SPCC Plan. ' SPCC Guldanceror RegionalInspectors,December 2,2005(hdoYlwww / 1/ t U G ce udancehfrn) Leder to Daniel Gilligan,President,Peholeum MaBeters Assodefion of America,from Marianne Lamont Horinko,Assistant Administrator Office of Solid Waste and Emergency Response,EPA,May 25,2004, 3 Further derails can be found in the Federal Register',73 FR 74265(December 5,2008). Office of Emergency Management 5