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Bulk Storage Container Inspection Fact Sheet July 2012 inspection program when industry standards do not apply to a container or the container is outside the scope of the standard. However, you must describe the procedures for this inspection program in your SPCC Plan and keep a record of inspections and tests for three years. EPA recommends that formal test records or reports be retained for the life of the container. What are some recommended elements for a site-specific integrity inspection andlor testing program (hybrid testing program)? The components of a hybrid inspection program would likely include frequent visual inspections by the owner, as well as periodic inspections(plus testing as appropriate) by a certified inspector. Any hybrid inspection program should include an evaluation of the principal elements that would cause a tank to fail, and how the inspection program addresses finding such conditions, or prevents such conditions from continuing to the point of failure. For example, internal and external corrosion conditions must be considered, and a testing method developed to assure that the condition is identified and measured. Conditions that may lead to a structural failure should be identified, for example a failing foundation, and evaluation methods developed to identify the condition. In all cases, careful consideration should be given to discovering such conditions that may not be identifiable from visual examination, such as the bottom of Floor plates. Hybrid programs should also include evaluation of container modifications made since last examination that may degrade integrity or lead to failure. Recommended Elements for a Hybrid Inspection Program Here is a partial list of items to consider regarding the elements of a hybrid inspection program. For shoo-built tanks: • Visually inspect exterior of lank; • Evaluate external pitting; • Evaluate"hoop stress and longitudinal stress risks"where corrosion of the shell is present; • Evaluate condition and operation of appurtenances; • Evaluate welds; Establish corrosion rates and determine the inspection interval and suitability for continued service; Evaluate tank bottom where it is in contact with ground and no cathodic protection is provided; Evaluate the structural integrity of the foundation; Evaluate anchor bolts in areas where required;and Evaluate the lank to determine it is hydraulically sound and not leaking. For field-erected tanks: • Evaluate foundation; • Evaluate settlement; • Determine safe product fill height; • Determine shell corrosion rate and remaining life; • Determine bottom corrosion rate and remaining life; Determine the inspection interval and suitability for continued service; • Evaluate welds; Evaluate coatings and linings; Evaluate repairs for risk of bridle fracture;and Evaluate the tank to determine it is hydraulically sound and not leaking. How do I inspect and/or test containers that store animal fats or vegetable oils (AFVO)? The inspection and/or testing requirements for AFVO at§112.12(c)(6)(i), are identical to those described above at§112.6(c)(6). The SPCC rule also provides differentiated, more flexible, alternative requirements at§112.12(c)(6)(ii)for AFVO containers that meet certain criteria to address differences in the way certain AFVOs may be stored and handled at a facility. Office of Emergency Management 7