Spill Prevention, Control, and Countermeasure (SPCC) Plan Requirement: Integrity Testing

If your organization is in the oil industry or your organization stores, processes, transfers, uses, consumes, or gathers oil or oil products over a certain amount, you are required to follow SPCC regulations. There are very specific rules that you should be aware of and ensure your business is following procedure. That’s why it’s a good idea to have an SPCC plan.

What is an SPCC Plan?

Before outlining a plan, let’s define the regulation. “Originally published in 1973 under the authority of §311 of the Clean Water Act, the Oil Pollution Prevention regulation sets forth requirements for:

  • the prevention of,
  • preparedness for, and
  • response to oil discharges at specific non-transportation-related facilities.

The goal of this regulation is to prevent oil from reaching navigable waters and adjoining shorelines and to contain discharges of oil. The regulation requires these facilities to develop and implement Spill Prevention, Control, and Countermeasure (SPCC) Plans and establishes procedures, methods, and equipment requirements (Subparts A, B, and C).” You can read the full regulation outline by going to EPA.gov.

The plan is a document that addresses your facility’s preparedness for a spill and an outline of your procedures should a spill occur. This document should inform the EPA that you are aware of the risks of an oil spill that you are armed with the right resources to correct such an accident.

Integrity Testing on Oil Tanks for Your SPCC Plan

If your facility is required to prepare a Spill Prevention, Control, and Countermeasures (SPCC) Plan, then you may also be required to conduct integrity testing on tanks meeting certain requirements. Let’s focus on tanks that were built to meet Steel Tank Institute’s SP001 standards. The SP001 standard applies to the following:

  • Aboveground storage tanks (ASTs), including shop-fabricated tanks, field-erected tanks, and portable containers.
  • ASTs storing stable, flammable and combustible liquids at atmospheric pressure with a specific gravity less than approximately 1.0.
  • ASTs storing liquids with operating temperatures between ambient temperature and 200 °F (93.3 °C).

If the above describes the types of tanks and products being stored at your facility, then you may be required to perform periodic integrity testing, either external, internal, or both.

The next consideration is the tank’s size and whether or not it is provided with a means of spill control (i.e., secondary containment dike, double-wall tank, etc.) and/or leak detection (i.e., double-wall or double-bottom tank, elevated ASTs, etc.). If you have a tank that is 1,100 gallons or below and no-spill control or leak detection is provided, then integrity testing is required. For tanks between 1,101 and 5,000 gallons, testing is required if no leak detection is provided. 

The interval between tests is dependent on several factors and can range from every 5 years to every 20 years. Once you’ve figured out how often integrity testing is required, then you need to set up a schedule and find a Certified Inspector to perform the inspections and any required tests. Portable containers with a capacity of 55-gallons or more, whether plastic, steel, or stainless steel, only require periodic inspections. If these containers are re-used, then they must either be removed from service or DOT tested and recertified according to the schedule identified in the standard. Examples:

  1. A 5,000-gallon horizontal, double-wall oil AST with overfill prevention is only required to have periodic inspections.
  2. A 1,500-gallon vertical, single-wall oil AST that is in contact with the ground and is provided no-spill control or leak detection is required to have periodic inspections and leak tests at least every 5 years, formal external inspections at least every 5 years, and formal internal inspections at least every 10 years.
  3. A 55-gallon steel drum that is reused and has been in service for 12 years is required to either be replaced or DOT tested and recertified before it can continue being used. Please note that oil-filled equipment is not considered a bulk storage container and is therefore not subject to integrity testing requirements.

Environmentally Equivalent Inspection Program

In certain situations, facilities may use an environmentally equivalent inspection program to demonstrate compliance with the SPCC regulations. This may be in the form of a site-specific inspection program designed to minimize the risk of container failure and allow the detection of leaks. You may only use this alternative if you include the reason for deviating from the rule requirements in the SPCC Plan and describe the alternative method in detail, including how

it is environmentally equivalent. In some cases, it may make sense to deviate only from portions of the industry standard, if another approach would be more appropriate or cost-effective, based on site-specific factors. Any equivalent program must be certified by a Professional Engineer.

The environmentally equivalent program should be able to measure the structural soundness of a container shell, bottom, and/or floor to contain oil, and may include leak testing. The elements of the program would most likely include frequent visual inspections by the owner, with periodic inspections and testing, when appropriate, by a certified inspector.

What’s Next?

If your facility has tanks that store flammable and combustible liquids, you may have to do more than perform routine inspections using facility personnel. Depending on the type of spill prevention and leak detection measures in place, additional inspections from a certified tank inspector may be required. To ensure compliance with integrity testing requirements, be sure to know what is required for the tanks on your property and perform and document all necessary inspection requirements.

 1. EPA. gov https://www.epa.gov/oil-spills-prevention-and-preparedness-regulations/overview-spill-prevention-control-and

 

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