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The SPCC Plan Hybrid Inspection Program

Posted on Thu, Sep 12, 2013

The Environmental Protection Agency (EPA) estimates that approximately 640,000 U.S. facilities are potentially subject to regulations under the SPCC Rule:

A facility that stores, processes, refines, uses or consumes oil and is non-transportation-related is potentially subject to the SPCC rule. The EPA requires SPCC plans for facilities that could discharge oil into navigable water and store more than 1,320 gallons aboveground or more than 42,000 gallons underground.

The SPCC inspection program is designed to detect oil leaks, spills, or other potential integrity or structural issues before a  spill occurs.  The type of inspection program, scope, and frequency will depend on site-specific conditions, spill history, and type of facility. Typically, inspection programs are in accordance with industry standards. However, companies can decide to deviate from industry standards when another approach would be more appropriate or cost effective, based on site-specific factors. The result may be a Hybrid Inspection Program.

The EPA classifies a Hybrid Inspection Program as a customized, site-specific inspection program based on relevant industry standards (in whole or in part) and other good engineering principles. According to the EPA, the components of a Hybrid Inspection Program would likely include frequent visual inspections by the operator, as well as periodic inspections (plus testing as appropriate) by an EPA certified inspector. A company must document environmentally equivalent inspection and testing alternatives, the reason for the deviation, and describe the alternative method in detail, including how it is environmentally equivalent in the SPCC Plan.

It is recommended that formal container test records or reports be retained for the life of a container under the Hybrid Inspection Program. When implementing a Hybrid Inspection Program, the EPA recommends the following elements:

Inspection elements for shop-built tanks:

  • Visually inspect exterior of tank
  • 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
  • Evaluate the tank to determine it is hydraulically sound and not leaking

Inspection elements 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 brittle fracture
  • Evaluate the tank to determine it is hydraulically sound and not leaking.

When industry standards do not apply to a container or the container is outside the scope of the standard, a PE does not need to provide and certify an environmental equivalence justification. However, specific inspection protocols must be described in the SPCC Plan, and records of inspections and tests must be maintained for three years. Containers included outside the scope of industry standard can include, but are not limited to:

  • Containers storing oils that have a specific gravity greater than 1.0
  • Oil containers operated at elevated temperatures
  • Animal fat or vegetable oils (AFVOs) containers

Regional EPA representative(s) conduct both announced and unannounced inspections at facilities. A copy of the facility’s SPCC Plan with site-specific inspection procedures should be available for inspector(s) to review at all times. Additional documentation,  including operating procedures, spill prevention measures, personnel training, drainage discharges, and spills should be provided to inspector(s), as well as site plans for tankage, diversionary structures, and drainage patterns.

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Tags: SPCC, Oil Spill, Training and Exercises, Regulatory Compliance, Chemical Industry