Prepare for summer by unlocking the secrets of storage tank integrity with local regulatory expert Shannon Oelkers. As the days grow longer and the temperature rises, we're reminded that it's not just about planning beach trips and barbecues – it's also prime time for tank inspections. Shannon brings her infectious enthusiasm to our latest episode, where she navigates the complexities of SPCC plans and the pivotal role of STI inspections. Guarantee your facility's safety and compliance as we reveal how industry standards like the STI SP001 are essential for above-ground container integrity.
Shannon's insight into tank inspections is a game-changer for facility managers responsible for SPCC plans. Learn about the crucial monthly and annual inspections that go unnoticed on paper but are vital for hazard prevention. Our conversation covers the dual components of tank inspection – the internal checks performed by facility personnel and the rigorous external inspections by certified experts. With Shannon's guidance, managing SPCC plans becomes less daunting and more about implementing effective strategies to meet industry benchmarks, ensuring your storage tanks are summer-ready and beyond.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
Prepare for summer by unlocking the secrets of storage tank integrity with local regulatory expert Shannon Oelkers. As the days grow longer and the temperature rises, we're reminded that it's not just about planning beach trips and barbecues – it's also prime time for tank inspections. Shannon brings her infectious enthusiasm to our latest episode, where she navigates the complexities of SPCC plans and the pivotal role of STI inspections. Guarantee your facility's safety and compliance as we reveal how industry standards like the STI SP001 are essential for above-ground container integrity.
Shannon's insight into tank inspections is a game-changer for facility managers responsible for SPCC plans. Learn about the crucial monthly and annual inspections that go unnoticed on paper but are vital for hazard prevention. Our conversation covers the dual components of tank inspection – the internal checks performed by facility personnel and the rigorous external inspections by certified experts. With Shannon's guidance, managing SPCC plans becomes less daunting and more about implementing effective strategies to meet industry benchmarks, ensuring your storage tanks are summer-ready and beyond.
This podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages, or liabilities that may occur from using this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
I'm doing really well. Spring has sprung and I'm really excited for the upcoming summer season. Things are really moving and shaking and I always like this time, right before we go out into the field. It's just full of anticipation and freshness.
Amanda:
Oh yeah, and summertime, that's when we pick up our tank inspections.
Shannon:
And summertime. That's when we pick up our tank inspections. It's true, we do most of our tank inspections when the air temperature is warmer than 34 degrees.
Amanda:
It's comforting. So I've noticed that SPCC plans and STI inspections often occur together. Why?
Shannon:
is that? You know we get that question from our clients a lot and the answer is a change to the SPCC requirement in 2002, but also an enforcement in 2011. There's a very specific part of the SPCC regulation, specifically 40 CFR 112.8.6. Let me quote directly from it Test or inspect each above-ground container for integrity on a regular schedule and whenever you make the material repairs, 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, tests and inspections, the frequency and type of testing and inspections. So this change to the SPCC code 10 years ago meant that all of the principal engineers that were reviewing SPCCs and approving them which is a requirement also of the SPCC plan they had to show that there was some sort of testing program of all the bulk fuel storage containers in accordance with industry standards. And for most SPCC facilities the appropriate standard is STI SP001.
Amanda:
What does the SP001 mean?
Shannon:
You know, that's a really good question and I just learned that during a training I took. So the STI stands for Steel Tank Institute and then the SP stands for Standard Practice, which means it's an industry standard practice. There's also language that says RP and that means recommended practice, and so recommended practice is sort of like best management practices, good ideas. Sp means standard practice and that means it's generally accepted by the engineering community as the standard practice for whatever the standard applies to. And then the 001 part means that it was created in 2000. And it's the first edition 1001.
Amanda:
That's pretty clever.
Shannon:
Yes, where would the standard apply? Well, that standard covers stationary tanks and it also covers portable containers and it covers mostly horizontal tanks but also some verticals, because the UL 142 and the UL 2085 construction standards they have a lot of flexibility, so you got a lot of different kinds of tanks out there. Flexibility, so you got a lot of different kinds of tanks out there, and so the STI broadly applies to pretty much every kind of tank sort of under the 75,000 gallons and even some up to maybe 200,000 gallons, but those are pretty rare. Generally, we see the STI SP001 standard applied to your very stereotypical horizontal tank that could be anywhere from 275 gallons all the way up to 50,000 or 75,000.
Amanda:
Wow. What do SPCC managers need to know about STI?
Shannon:
When an engineer selects the STI standard for your tank inspection program, there are two components to it. One is an in-house component where somebody knowledgeable about the tank and its operation from the facility performs a monthly and an annual inspection. And when we audit facilities we frequently find that that's not being performed on paper. The terminal manager, of course, is looking at his tank and he notices if something's not right or, you know, is out of whack. But documenting it on a piece of paper monthly and annually, specifically in the STI format, doesn't happen as frequently. So if I was managing an SPCC plan I'd want to make sure that I understood that there is a monthly and an annual component to that that you're supposed to be doing internally. And then there's an external component where an STI certified inspector has to inspect some kinds of horizontal tanks but not all and so smaller tanks that are fully within secondary containment and have certain spill control and overfill prevention devices. You will only ever need to do an internal inspection to make sure that things are correct and meeting the STI standard. But as tanks get bigger, the risk for an overfill or a spill gets bigger, right, because there's more fuel to spill, and so the STI standard generally tanks over 5,000 gallons in size or tanks that are not within a secondary containment system. They require inspection by a certified inspector from outside your company that has special certifications and they come and they actually inspect the tank, they take some UTT data and they also create a formal external or internal inspection report for your tank, depending on what kind of tank. That report will typically include photos and they'll map out your tank and the appurtenances and it's a really good document for your tank, just to know more about your tank.
Shannon:
But it's also something you have to keep for the life of your tank and the SPCC refers to that and requires those external inspections for those specific tanks.
Shannon:
So somewhere in your SPCC plan you have a table and in that table it says when your tank inspections are due and who is to perform them, and sometimes people who have older SPCCs that they haven't updated recently.
Shannon:
You're supposed to require to update it every five years but sometimes that falls by the wayside and the older SPCCs that are older than 10 years sometimes don't have the inspection schedule because it wasn't a requirement like it is now in the modern SPCC world. So if you're an SPCC manager, those are the two things I think you really need to focus on is that those tanks are supposed to be having monthly and annual performed in-house, and that some of your larger tanks will have an external component and the reason when our firm gets called for an SPCC. Oftentimes we're the first one to have rewritten the SPCC or we're creating a new SPCC and the tanks have been on site for a long time but have never been inspected, or they don't have any inspection records that have been kept, and so for our PE to sign off on, we have to have an STI SP001 inspection record, especially for the bigger tanks.
Amanda:
So that's why they go together. All right, and that sounds like a pretty thorough inspection. How would someone go about finding a certified STI inspector?
Shannon:
Well, you could call us and we have several on staff. You can actually write to STI and get a list of the certified inspectors that are current and you can sort that Excel sheet by state or location or region. You also want to make sure when you are hiring an STI inspector that their STI inspection credentials will be current when they're performing the inspection. We've had a couple that clients have provided to us to review where the STI inspector his certificate expired before they went out to the site, like it was current when they made the plans but then of course it exceeded that. So you're going to want to make sure that they have that current certification. And, yeah, you can go directly to the STI SP001 website, which we can absolutely leave in the show notes, and there is a button to request a list of STI inspectors and you can sort of cross-check or go shopping using that list. Look for me, I'm on it.
Amanda:
That's convenient. What should we be looking at in the STI report when it comes back specific to the SPCC requirements?
Shannon:
For a formal external or internal inspection by a certified inspector. You're going to want to look for a couple of things. The SPCC program wants to make sure that you have adequate secondary containment measures and the STI allows for different kinds of spill prevention methods and they don't always match up with the SPCC. For example, a double-walled tank. The double wall acts as a secondary containment Under an STI inspection. If there is a double walled tank and there's overfill prevention provided by a person attending all filling events, that's considered a category one tank and it's good to go. You don't have to have it inside secondary containment. But the SPCC regulations have additional stuff on top. They say you have to have specific overfill prevention devices installed on the tank for that tank to not be within secondary containment.
Shannon:
So, that's one thing you want to look at is to make sure that your SPCC requirements match with what the STI report is reporting back and not assume that because the STI says you're good to go, that you're good to go with the SPCC, the SPCC trumps the STI.
Shannon:
The other thing you're going to want to look for is to make sure your report is thorough and has lots of photographs and if they say something like if nozzle C appears to have damage, that it actually identifies what the inspector thought nozzle C was. It's got sort of a diagram or a figure that shows where all the things this person is talking about the inspector is talking about, so that you can go and look at your own tank and identify those things. The other thing you want to look at is the inspection intervals, because for STIs most of these inspection intervals are a formal external every 20 years if everything's good on your tank. If your tank inspection interval is lower than that 10 years, 5 years that means that you're missing some critical components like release detection or spill control, and you can extend the length of time between inspections if you add things like an impermeable containment area or a dike or add an overfill prevention alarm to your tank.
Shannon:
So, sometimes if you get an STI report back and they say, oh, we've got to come back in five years, if I was in your position of reviewing these reports, I'd be like, well, what could I do to make that 10 or 20? What could I do to this tank that would then make me a different category of tank and allow me to have a longer formal inspection interval.
Amanda:
All right, and is there any guidance from the EPA surrounding portable containers?
Shannon:
Yes, the EPA issued a bulk storage container integrity testing guidance and we will link that in our show notes. The EPA asserts, rightly so, that tanks are not the only thing that can leak Containers can too. And so if your containers are a bigger size, over that 55-gallon threshold, they want to know that you're doing integrity testing and inspecting and monitoring and preventing leaks and spills so that you're not impacting the environment. And this guidance is a little thick. It does talk about developing a program for inspecting or testing your containers, and that is something that everyone needs to have.
Shannon:
It doesn't have to be difficult. It can be simple, but, as you know if you've listened to this podcast before, simple is not always easy, and so it does help, especially if you've got a facility with multiple tanks, containers and all sorts of things going on. Firms like ours can be a good help of sort of helping you set up that inspection program and making sure you know how to run it and provide training for people that are filling out all these monthly and quarterlies and annuals. But if you're a DIYer, you can get most of that information from the EPA as well. And then the STI website also has some pretty good guidance on portable containers and they have a free inspection checklist for portable containers.
Amanda:
Perfect. Well, we'll include that in the show notes so our listeners can jump in.
Shannon:
Yeah, if people have questions, they're more than welcome to reach out to me and run them by me. Portable containers make things a little complicated and so, yeah, if you have a question, feel free to drop me a line in an email and I'd be happy to help you out. Since we're done with today's run through of SPCC and STI BFFs forever, I was thinking we could put a link to the STI website and on there you can request that list of inspectors. You can also download for free the monthly and annual inspection checklist examples, and we can also include that PDF straight as a link in our show notes. And then I will definitely put a link to 40 CFR 112. So you can go read that regulation yourself, if my version of it was not satisfying.
Amanda:
I doubt it. Well, thank you so much, shannon, for joining us today and explaining how SPCC plans and STI inspections work together, and I look forward to our next chat. Yeah, thanks, amanda.