COMPLIANCE INFO - Laserfiche WebLink

Home Browse Search

Bulk Storage Container Inspection Fact Sheet July 2012 Furthermore,the Plan must provide the reason for the deviation, describe the alternative approach, and explain how it achieves environmental protection equivalent to the applicable industry standard. How do I inspect mobile or portable bulk storage containers? Industry standards(such as STI SP001) refer to specific conditions for which visual inspection alone is an appropriate method for verifying the integrity of certain smaller shop-built containers (e.g., portable containers such as drums and totes). These conditions include container type, size, and configuration (such as whether the container is in contact with the ground or has appropriate secondary containment). For example, according to STI SP001,when portable containers have adequate secondary containment then visual inspection of these containers is acceptable and will satisfy the integrity testing requirements of the rule. Do I have to use an industry standard? No. Although the rule requires that you consider industry standards when developing an inspection program, you can incorporate an environmentally equivalent inspection protocol when you and the certifying PE decide that another approach would be more appropriate or cost effective, based on site- specific factors. You can use an environmentally equivalent alternative when you include in your SPCC Plan the reason for deviating from the rule requirements and describe the alternative method in detail, including how it is environmentally equivalent. An environmentally equivalent approach to following the applicable industry standard may be a site- specific inspection program that is based on elements designed to minimize the risk of container failure and allow detection of leaks before they impact navigable waters or adjoining shorelines. These elements may be based on a combination of various industry standards and good engineering practice. Can I deviate from portions of an industry standard? Yes, under certain circumstances it may be appropriate to deviate from portions of an industry standard. As you develop your inspection and/or testing program, you must determine, in accordance with industry standards,the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration and design. However, you and the certifying PE can decide to deviate from a portion of a standard when another approach would be more appropriate or cost effective, based on site-specific factors. You must document your environmentally equivalent alternative, the reason for deviating from the rule requirement, and describe the alternative method in detail, including how it is environmentally equivalent in your SPCC Plan.4 An environmentally equivalent approach to following the applicable industry standard may be a site-specific inspection program based on a combination of elements from various industry standards and good engineering practice, or other measures that effectively minimize the risk of container failure and that allow for the detection of leaks before they impact navigable waters or adjoining shorelines. What if no industry standard applies to my container? If no industry standard applies to a particular container(e.g. Animal Fats and Vegetable Oils (AFVOs) containers, containers storing oils that have a specific gravity greater than 1.0, or oil containers operated at elevated temperatures),then the Plan preparer should consider the manufacturer's specifications and instructions for the proper use and maintenance of the equipment, appurtenance, or container. If no industry standards or manufacturer's instructions apply,the Plan preparer may also call upon his/her professional experience and/or consult with tank inspection professionals to develop site- specific inspection and testing requirements for the facility or equipment that are in accordance with good engineering practice and document them in the Plan. A customized, site-specific inspection program based on relevant industry standards(in whole or in part) and other good engineering principles is often referred to as a 'hybrid' program. A PE does not need to provide and certify an environmental equivalence justification for implementing a hybrid 4 See 73 FR 74264(December 5,2008) Office of Emergency Management 6