STI SP001 with Experts

In this episode of Tank Talk, host Shannon Oelkers sits down with two seasoned experts - Joe Mentzer, Standards Engineer at the Steel Tank Institute (STI/SPFA), and Craig Fletcher, Principal of Fletcher Consultants, Inc. - for a deep dive into the STI SP001 standard and what it means for those managing aboveground storage tanks. 

With over 60 years of combined industry experience, Joe and Craig bring unparalleled insight into the purpose, evolution, and practical application of one of the most widely used standards in fuel storage compliance. 

Tune in as the conversation explores: 

• The mission and role of STI/SPFA in supporting steel infrastructure and tank safety 
• The history and intent behind STI SP001 
• The differences between industry standards and recommended practices 
• Clarifying the roles of Owner’s Inspectors vs. Certified Inspectors and what “qualified” really means 
• How spill control and CRDM impact tank categorization 
• What tank size really tells us about risk 
• Key points tank owners should focus on in inspection reports 
• The critical importance of routine water draws to prevent corrosion and microbial issues 

The episode also includes a lightning round addressing common questions from the field about tank inspection forms - from concrete cracks and coating failures to grounding and overfill prevention valves. 

Joe and Craig also highlight free and low-cost resources available through STI/SPFA to help operators, owners, and environmental professionals stay informed and compliant. 

🎧 If you work with shop-fabricated tanks, write SPCCs, or just want to improve your tank inspection programs, this episode is packed with real-world answers and actionable insights. 

STI/SPFA - Representing the Steel Fabrication Industry

SP001 Standard for the Inspection of Aboveground Storage Tanks - STI/SPFA

Chapters

• 0:10 Welcome to Tank Talk
• 3:36 Meet the Tank Experts
• 10:21 History of STI SPFA Organization
• 17:26 Understanding STI SP-001 Inspection Levels
• 31:02 Tank Categories and Risk Assessment
• 43:20 Water Management in Tanks
• 55:43 Tank Installation and Commissioning
• 1:08:20 Lightning Round: Common Inspection Issues
• 1:24:32 Final Advice and Resources

Transcript

Haley Hall: 0:10

Welcome to Tank Talk with Integrity Environmental. Join us as we sit down with founder, principal consultant and bulk fuel storage expert, Shannon Oelkers, to explore regulations, safety and essential tips for navigating the bulk fuel storage industry. Join us as we explore the unique joys of work and life in Alaska with industry experts, including our team, vendors we work with, and the companies we support.

Shannon Oelkers: 0:36

Hello, welcome to Tank Talk. This is Shannon Oelkers here, and I am very excited today because I have two very special guests. I have Joe Mentzer with the STI SPFA organization, and then I have Craig Fletcher from Fletcher Consultants Inc. Both are recognized experts in above ground storage tanks. I have taken classes from both of these gentlemen that I have enjoyed greatly over the years. I've taken two from Joe, and Craig Fletcher was the one that got me my STI certification for certified inspector. I'm so glad to have both of you here today to talk about the STI SP-001 standard. So welcome. I appreciate you being here so much. Glad to be here.

Shannon Oelkers: 1:17

Yeah, Before we get into the STI, which I am dying to do, STI SP-001. I was hoping you guys could introduce yourselves briefly and maybe give me a brief overview of your career, how you fell in or backed into tanks and then we'll start talking about the STI SP-001.

Joe Mentzer: 1:35

My name is Joe Mentzer. I am the standards engineer for STI SPFA, which is the Steel Tank Institute Steel Plate Fabricators Association. I have been in this role since 2019. Prior to that, I was a consultant in Wisconsin and I did stuff with people who stored just about anything.

Joe Mentzer: 1:55

When I started working in the environmental world, I would address spills, mostly from underground storage tanks, and I cleaned up a lot of tanks and I finally had one of my first customers in fact may have been one of my first customers says great, you can clean it up, can you make it not leak in the first place? And that was sort of my business plan. The other part was, as they were cleaning up or replacing gas stations, they would run into problems and it would interfere with the installation. So, since I was doing the cleanup, I had to learn the installation process so I could facilitate cleaning up the site and installing it. Well, then it moved to above ground tanks and then it moved to.

Joe Mentzer: 2:32

I worked with a lot of weird chemicals the printing industry, the food industry, the pharmaceutical industry so then I got into the hazardous stuff and I was a consultant for many, many years and I was a SPO1 inspector since 2001. My state adopted that early. Wisconsin is where I did most of my work Adopted that program early, I got involved with that and I met the folks at STI and then, when my predecessor retired, the job opened up and consulting had been a good run, but it was time to try something different. So I ended up moving here. But I've worked in the petroleum industry, certainly, but also several other industries that store really interesting stuff.

Shannon Oelkers: 3:14

Spoken like a true engineer. Chemicals, that would make my hair go gray. You're like that's interesting.

Joe Mentzer: 3:20

Like this chemical. It looks like water, it has no odor, but if you get it on your skin it might kill you. Oh, okay.

Shannon Oelkers: 3:26

Great. That's how I feel about methanol. It can be on fire and you would never know.

Craig Fletcher: 3:30

That scares the crap out of me.

Joe Mentzer: 3:33

Yeah, that's another one, all right.

Shannon Oelkers: 3:36

So Craig, you want to introduce yourself.

Craig Fletcher: 3:38

Sure, I'm Craig Fletcher. I'm the principal of Fletcher Consultants. We're a small California-based environmental consulting firm that does a wide variety of environmental consulting services for a host of clients. In terms of the company itself, we've been around about 23 years. We provide everything from preparing SPCC plans, spill prevention, control and countermeasure plans to hazardous waste tank certifications, as well as doing many other types of environmental compliance stuff, including hazardous waste facility permitting. We've also done a whole variety of soil investigations and other types of work.

Craig Fletcher: 4:14

Getting back into the, I've been an STI inspector since 2009. And early on when the SPCC plan regulations were being changed, I recognized early on the need for having because of the requirement to have the following an industry standard, the need for having the training in the STI program and becoming certified. So that's kind of it in a nutshell. Prior to starting this firm, I worked for Pacific Gas and Electric Company, pg&e, the utility out here for 10 years and that's probably where I first got more into tanks, where I worked at a power plant where we had about I think it was 18 or 19 million gallons worth of petroleum storage there. So it was a very complex facility that had a lot of different aspects to it. Prior to that I was in grad school. Prior to that, I worked in environmental consulting as a geologist. Before then I was actually I worked in exploration geology for Chevron, USA. So that's we're getting back into the just the wooly mammoth perished, but in terms of my career. But that kind of gives you the nutshell.

Shannon Oelkers: 5:19

Okay, and then, Craig, you have a geology background, is that correct?

Joe Mentzer: 5:23

That's true.

Shannon Oelkers: 5:23

And then Joe, you're okay, yeah, I have a geology background. Is that correct? That's true. And then, joe, you're.

Joe Mentzer: 5:25

Okay, yeah, I'm a professional geologist. And then, joe, you're engineering. Yeah, I am an engineer. I'm actually a mining engineer. I got my degree in Madison, Wisconsin, in mining. I like geology.

Shannon Oelkers: 5:34

Okay, I do too. Surprisingly, I have a biology background. I don't know how I ended up here, but I love it. So thank you both for agreeing to be here today to talk about the STI SP001. Our longtime listeners, they know how much I love to talk about STI and there's a good reason for that.

Shannon Oelkers: 5:55

I think 99% of the facilities we work with have shop fabricated or shop built tanks as part of their inventory and there's a lot of regulatory ties, as Craig mentioned, to the STI SP00 standard in particular, both with the SPCC and then for our Alaskan-based clients. We also have ODPCP that requires tank inspection to an industry standard as well, and then we also sometimes have client requirements for the STI inspection as part of their risk mitigation, maintenance and operation planning. So STI SP001 is part of the STI SPFA standard library and I'm very excited to dig into the history and the application of this widely used standard. And then I'm really excited to maybe get some clarity on some things that we've noticed over the years, that there's questions we got, so I'm excited to get answers to them. So let's start with who STI SPFA is.

Shannon Oelkers: 6:46

What is the purpose and role of this trade organization?

Joe Mentzer: 6:50

So it's a merger of two trade organizations. I think the merger happened somewhere around 2000. It was the Steel Tank Institute, which had been around since, I think, 1916. It was actually got together during World War I because tanks were a important war material. So a group of manufacturers got together to make sure that the war needs were met with production. But after the war obviously you can't coordinate like that. But they did stay in touch because there were rules and regulations associated with the construction of tanks. The UL 142 standard, the standard that a lot of shop-built stuff is built to, has been. My earliest version is 1922. So they had to stay kind of involved to make sure that the rules were consistent and something they could work within.

Joe Mentzer: 7:41

Steel Plate Fabricators Association, that's an organization whose members built lots of infrastructure out of steel plate. It was large storage tanks, certainly Pipelines, all the other infrastructure associated with managing all those things. And again, there's rules, there's regulations. There's got to be consistency in the product for just history and safety. And so those organizations both tracked how things were built, how things were produced, what rules applied, got involved with the standards and rules that affect them, because you don't want somebody writing some standard that yeah, I can't do that. I sit on several rules committees. I worked with those standards for years. Now I get to help write them. It's interesting, but you got to make sure that there has to be involvement by people familiar with how things are built and especially, you know, the tank guys, the tank builders. Some of these companies aren't that big. They really don't have enough people that they can assign someone the job of tracking that. So they participate in an organization and make sure that their voices are heard.

Joe Mentzer: 8:46

We have members all over the world. I deal with people in Australia and China and the Far East, not much in Europe. They have their own rules. Certainly, south America, canada, the Canadian rules are different, but there are some similarities but they are absolutely different. So that's kind of the history is to stay involved. And then we also have members who make the stuff that support the tanks, the vents, the coatings, pipe. Every, I think the chemical folks and the water folks, the water infrastructure uses similar rules. The standards for water tanks they're just due to the way that water tanks are used. There are significant differences, but there's a lot of things that are the same too. So that's why the organization is there to make sure that the resources and the information gets distributed properly and people can react, and make sure that the industry can provide the infrastructure that's needed.

Shannon Oelkers: 9:49

I didn't realize it had such a broad spectrum. I've only dealt with it for steel tanks for fuel so I didn't realize it included water and chemicals.

Joe Mentzer: 9:55

Oh well, it's really interesting. Yeah Well, maybe not up in Alaska, but down here it seems like every municipality has a water tank, because they pump the water up to the top of the tank and that's what helps hold pressure constant. You need those things water and sewer one of the first two things you need to really have a community. We do have some water tanks.

Shannon Oelkers: 10:19

Palmer has one. I'm not actually sure if there are any others in the state. The only one I know of is in Palmer.

Joe Mentzer: 10:25

I'm not actually sure if there are any others in the state. The only one I know of is in Palmer. In cold weather locations they can become difficult because you don't want to end up with a big icicle hanging up in the breeze. It can be done.

Shannon Oelkers: 10:33

We also have a lot of lakes and pure water in Alaska, so we in a lot of yeah. We may just not need it like you do in the flatlands.

Joe Mentzer: 10:39

Yeah, and you know, and sometimes it's just a small tank but it's on top of a hill and that gives it the grade it needs, so it maintains pressure.

Shannon Oelkers: 10:47

Yeah, we have a lot of those in Alaska for sure. All right, so thank you for answering what SPFA meant, because I did not know what the initials stood for, so I appreciate that. So you mentioned 1916 for the Steel Tank Institute; so the STI SPFA has been around for over 100 years now

Joe Mentzer: 11:06

Yeah, and we have on the wall in the office. We have what they call the Century Club. We have tanks that are over 100 years old. Those are water tanks Honestly, the oldest oil tank.

Shannon Oelkers: 11:17

I know two oil tanks that are older than I've got, one from 1914 and one from 1917 that are still in service.

Joe Mentzer: 11:23

The oldest one I ever took care of was, yeah, 1933. It was half riveted half welded.

Shannon Oelkers: 11:29

We have a lot from the 30s and 40s because they were brought up with the World War II mobilization.

Shannon Oelkers: 11:35

And then they've just been in service ever since, and all along the different communities for the Alcan and also out in Kotzebue, Nome, A whole bunch of them in Fairbanks got distributed all over the state. So there's a bunch that were in Fairbanks that got sent down to like Kenai, for example. So we have lots and lots. In the thirties and forties there used to be three that were from the 19 teens that I knew about, but one of them did get taken out of service in the last five years but they were built by logging companies, if you can believe that to serve the logging industry in Southeast Alaska and they were riveted originally and then back-welded All right.

Shannon Oelkers: 12:10

So, as you guys know, most of our listeners work for companies who store fuel in bulk. They interact with your STI SP-001 standard the most. What is the ultimate goal or outcome for this standard? What is your hope for people that are interacting with this standard?

Joe Mentzer: 12:26

Well, happy, trouble-free operation of a storage tank so that asset performs the job that the customer needs it to perform. But it also doesn't become a liability during either normal operation or even unusual circumstances. I always look at that thing. I don't know, it's either like a puppy or a piggy bank. It always requires a little bit of attention, but if you take care of it it will deliver the goods. On the other hand, if you don't give it its due, all of a sudden your several thousand dollars of petroleum product will become tens and even hundred thousand dollars of an environmental liability. Or people can get killed or people can get badly hurt.

Joe Mentzer: 13:11

The rules that we deal with came about because of events that ended up. You never want to end up on the evening news. In the later 80s there was a failure of a tank in Pennsylvania and it released close to a million gallons of fuel oil. That got into the river and it headed down the river and it was affecting people's water infrastructure. It was getting into people's water systems. I know a guy who he responded to that and his job. He got in his car and he drove down the river and told everybody to turn off your water inlets so that you didn't pump fuel oil into your water system. And it was that event.

Joe Mentzer: 13:48

It was in Pennsylvania, it was that event that helped implement the SPCC rule and it created the first tank inspection standard, api 653. And in response to that, because the government said, either told the industry you got to come up with a way of inspecting your tanks or we're going to write the rules for you. But our goal is that you can safely operate your tank in an effective manner, that you can be confident that you know it's going to be there when you need it and it will respond in a reliable manner. Likewise, if it's exposed to a fire, it will respond again in a reliable manner. It won't explode. So that's what we're shooting for.

Shannon Oelkers: 14:27

That's a really good summary. I like that.

Joe Mentzer: 14:30

SP001 is a minimum inspection standard. We don't want to make it too onerous, but you got to do enough. But yeah, that's what we want. We want happy tank owners whose asset performs the job that they want it to perform and it doesn't become a liability.

Shannon Oelkers: 14:47

I really like that summary. I feel like everyone listening to this sometimes feels that they look at STI as a list of rules to follow, but I like the overarching goal of follow these rules and your asset will perform the way it's supposed to and maintain its value and do what you need it to do. I really like tying it to that. So this is probably another question for Joe, but we do get this question a lot. STI has industry standards and then they also have something called recommended practices and I was kind of hoping you could cover what the difference was between those two.

Joe Mentzer: 15:19

And I was just at an API conference and I asked the world's expert on that Her name is Marilyn Shores, just to make sure I got the right answer right. But no standard goes out from API without Marilyn sort of waving her thumb in the air. So an industry standard is very specific, it's very prescriptive, it has numbers and sections and very specific requirements to be met. Recommended practice if you're regulated, they both can be used to beat you over the head. But a recommended practice is much more I won't say vague, but it's more. Here's ranges of things to meet, here's recommendations. There's a lot more in standards. There's a lot more thou, you shall do this, you will do this, whereas practices you should consider doing this, you should look at this, these sorts of things. So they're much more specific.

Joe Mentzer: 16:08

One can evolve into the other at any point in time, but again, the practices are a little more vague. The standards are much more prescriptive. But the regulators can pull both out and say what are you doing to address this? And then it's up to really you to say we've done this or it's recommended, but we don't think this is a suitable recommendation here. But you better have something to back it up. So one is much more specific, one is a little bit more vague, but both of them have to be considered EPA. If you look, they have their definition of good engineering practice and it's not a vague term. It's actually got about a three or four paragraph description. And then OSHA has something called REGAGEP, recognized and generally accepted good engineering practice. Same thing. I mean you look at all the things that those agencies can pull out of the file cabinet and start pointing out why aren't you doing this? So there's a wide range of things to consider and you got to remember those agencies cover more than just distillate petroleum.

Craig Fletcher: 17:12

Just to add on to that a little bit, Shannon, is that the way the EPA described it in the Federal Register basically said that industry standards include industry regulations, standards, codes, specifications, recommendations, recommended practices, publications and specifications, recommendations, recommended practices, publications and other materials, and that's really all part of what we call good engineering practice.

Craig Fletcher: 17:31

And so how we get in industry standards, that was really, as you know, brought in through the regulatory changes that happened in the SPCC program. So the other difference between recommended practices and industry standards and an actual regulation is it's a little bit different in terms of how they're actually developed. Most industry standards like SP-001 or even a construction standard like UL-142 are developed through a consensus process with a group of experts and other interested parties. That differs somewhat from what we have in true regulations or statutes that are written by legislators. So the key thing that essentially happened in the 2000-2008 timeframe is when EPA said you must follow an industry standard for inspecting above-ground storage tanks or bulk storage containers. So it's usually once they put that reference in there in a regulation, you're kind of stuck to have to do that unless you're doing something pretty crazy. But that's kind of how it got weaved into the SPCC program. Craig brings up a good point.

Joe Mentzer: 18:37

If you look at the people that were involved in just SP-001, you see tank builders, you see people who own tanks and use tanks, you see service providers for tanks and you see regulators. So it's a big compromise and at the end everybody kind of had to say, yeah, this is good. I don't think everybody got everything they wanted, but my dad's definition of a perfect compromise is a solution that has everybody about the same level of ticked off, and that's kind of how those things work? No, it's not perfect.

Shannon Oelkers: 19:08

That sounds like such a Midwestern saying.

Joe Mentzer: 19:10

Well, it's not perfect, but we can work with this.

Shannon Oelkers: 19:14

Well, it goes back to the minimum of a standard. Right, like, the standard is the minimum acceptable to get the outcome. It doesn't include all of the bells and whistles and you can certainly add those if you want to make sure your asset performs better, but the minimum must be adhered to.

Shannon Oelkers: 19:28

I appreciate both of your views on this, because we do get a lot of questions like oh, it's a recommended practice, I don't have to do it, I'm like well that's not quite true, I don't think, and so I appreciate the clarification on that and I really like the definition that the EPA provides Craig about good engineering practice, because that is in there, it is 100% in there. But tying that to you should also follow this for how API says youick the best. But there's layers of inspection built into STI and I think this is one of our most misunderstood parts by our clients when they're implementing an STI program. Could you talk a little bit about the difference between an owner's inspector and a certified inspector within the STI SP-001?

Craig Fletcher: 20:23

Sure. So the owner's inspector, which is typically those are people who are at the facility, usually not always, but they're the ones performing what we call routine inspections or periodic inspections. And for stationary tanks that's, under the SP-001 standard, going to be a monthly and an annual inspection. So you do 12 monthlies and one annual inspection because the checklists have different criteria in them but within the standard itself it does talk about the owner inspector qualification. So those personnel have to be knowledgeable about the storage facility operations, the types of AST and its components, the spill control system for the facility and what they're storing. They also need to be familiar with how their pumps and piping work and valve operations of the AST system are put together.

Craig Fletcher: 21:09

Now, the idea behind these routine inspections, primarily the monthly and annual, is that getting eyeballs on an above ground tank is always good because it's above ground, we can see it and this is really the first line of defense. So the qualifications for those individuals they need to follow what they need to know what they're looking at and know actually what's on their tank system. And we know from experience conducting training to people writing SPCC plans that the experience level of individuals at a facility varies dramatically. Now, most of the time, the monthly inspections are relatively straightforward and you can get these inspection checklists directly from STI, spfa. Of course they're also included in the standard and most of those can be done without too much difficulty. I'm just speaking from a practical level here. Probably the one that gets people a little bit perplexed in some cases is the requirement for checking for water and tanks, and maybe we'll talk about that a little bit later.

Shannon Oelkers: 22:05

Yeah, that's a whole nother. Yeah, let's address that specifically.

Craig Fletcher: 22:09

Now, having said all that, the annual inspection is more detailed and, shannon, you've been through the class and we went through that in quite some detail in the training for the certified inspectors, which is another type of inspection that's done by qualified, trained inspectors. And to be able to do that, those require you to actually go through the class, take the exams, or you can also test in if you're an API 653 inspector. Regardless, there still is a minimum qualifications for that. So that's kind of a separate thing, but I would think, generally based on the kind of question you asked really is what about these routine inspections done by owners and what kind of training do they need to have?

Craig Fletcher: 22:49

Getting back to the annual inspection, it is challenging, I will say, because, especially for people not deep in the weeds in terms of knowing what's on tanks and when we were working with the inspection checklist just last year as part of the SP-01 revision that came out in February 2024, we wanted to make sure we were really trying to put out there. What we're trying to do is cover all different types of tank systems that are out there. But it's not uncommon for some folks to need help on doing those annual inspections because they are fairly involved doing those annual inspections. Because they are fairly involved Now in some facilities. Depending upon where you're at, our firm will come out and do training at a facility. Based on that, particularly if you set up your SPCC plan, then we'll be able to know what's on your tanks and which questions apply in that checklist and which ones may not apply Other times.

Craig Fletcher: 23:41

There are tank inspection companies that are retained to do annual inspections on behalf of clients. That's not required. There's no certification needed to do the periodic, the monthly and annual inspections, just as long as you meet the minimum criteria. So that's the routine or periodic inspections. As I mentioned before, the certified inspection is much more typically infrequent but it does require an actual certification from STI to perform those and much more involved.

Shannon Oelkers: 24:11

So, to summarize, owners representative or owners inspectors they can be somebody at the facility. They could also be a third party for particularly the annual I think for most of our clients they have. The monthlies are performed by staff that are operating those tanks every day, and my understanding of the monthly is it's like an early warning or early detection system. Almost everything on that monthly checklist is is there something happening to this tank that we need to bump it up the chain? And then same thing with the annual, sort of a more in-depth picture on things that could become a problem later if they're not addressed early. And then all of that is supposed to be done on a routine basis every month, every year, and I'm glad that you pointed out, craig, that there's 12 monthlies and one annual. We have some people we start working with and they've only been doing the annual because they think it's inclusive of the monthlies and they don't need to do the monthlies. But you have to do both.

Shannon Oelkers: 25:05

And, joe, I cannot tell you how thankful I am that STI publishes the monthly and annual inspection checklist for free, available for everyone.

Shannon Oelkers: 25:12

That has done more to standardize this industry than anything else. Like nobody has to buy the several hundred dollar inspection standard to get those inspection forms and it allows us, and probably Craig as well when you issue SPCCs you can have the same form in every single one and you can train people to the standard and it doesn't vary. When we first started and I've only been in business 15 years, but 15 years ago there was a lot more like homemade monthly and annual forms that included a lot of other stuff, and over the years I've seen it go away from that and having that STI inspection record for your tank, having the monthlies and annuals, and then your certified inspector needs to review those monthlies and annuals when he or she shows up to the facility to do their more in-depth certified inspection. Craig, could you talk a little bit about certified inspection though? Maybe just in general, like what does a certified inspector bring to the table? That goes beyond what the owner's rep would.

Craig Fletcher: 26:05

Well, typically, a certified inspection is much more involved in terms of what we'll certainly look at all the things that are on the monthly and annual inspection checklist. However, certified inspectors are obligated under the standard to prepare their own detailed checklist that cover not only all of that but other aspects that are described in the SP001 standard. So there's a number of other things that certified inspectors will do, including doing, essentially, a drawing or a sketch of the tank. As well as identifying all the appurtenances and key features on the tank, we'll also take a look at everything from the foundation to the venting to the piping, looking for evidence of problems on the system. And one other consideration that's slightly different than the API 653, which is the inspection standard for larger tanks generally, is that the SP-001 standard covers not just the tank. It includes the stuff attached to the tank, and so that's where we look at things like venting, both normal and emergency venting.

Craig Fletcher: 27:04

We look at valves and fittings and anti-siphon valves and a whole host of other things that are, and we'll take a deeper dive into those than what you would do for just a quick visual inspection. Most of the certified inspection is visual inspection, although it's often supplemented with other types of testing. In particular, for single-walled tanks and, in some cases, double-walled tanks, we will use ultrasonic thickness test measurements to determine what the remaining steel thickness is, but by and large, it really is sort of a much more in-depth inspection that's done by a qualified individual. These aren't particularly common inspections, but they are very valuable for facilities, not only for making sure that they're meeting the minimum criteria and the standard, but even also for maintaining asset value and asset life, which is something that I consider to be very important as a potential owner.

Shannon Oelkers: 27:58

With the price of steel these days. Yes, that is critical. I'm just going to add one thing Tanks are very valuable.

Joe Mentzer: 28:04

Craig hits upon an important point. Remember, there's all sorts of tanks that fall under SP-001, starting with it does cover portable containers, which five-gallon drums all the way up to a 75,000-gallon double-wall tank. So that's where the certified inspector they've got to be able to walk up and correctly evaluate what the system is and make sure everything's there. But also, with the monthly and annual inspection, it's pretty simple. On a smaller tank, Some of these larger tanks, it can be very involved, or involved, especially the annual involve a trip to the top of this 30, 40 foot tall tank to make sure that the equipment up there is operating correctly. So the smaller tanks, yeah, those are pretty straightforward. Some of the bigger ones, or if it's not storing petroleum, if it's storing some funky chemical, then all of a sudden you need to have an elevated level of education, experience and training. So, yeah, the SBO1 standard covers a lot of things, and so you got to be specific enough, but also not too specific in how you set things up so that it can be performed.

Shannon Oelkers: 29:16

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Joe Mentzer: 30:21

Those create new and different challenges.

Shannon Oelkers: 30:25

Generator-based tanks. Let's leave those off the table for today. Joe.

Shannon Oelkers: 30:29

I can't deal with generators in the morning, but I do want just people who are listening. If you're sitting in the seat of, I need to hire a certified inspector to come out. It would behoove you to check their resume and make sure that they understand the kind of tanks that you have and that they've got experience enough to be able to give you, in addition to the certification, that they understand the tank and the product that you're storing and have that background. Okay, so let's move on to tank categories, because that sort of informs how often these certified inspectors come in. Could we talk about the three tank categories? They're based on the presence or absence of two different things that STI has identified. One is called spill control and the other is something everybody in the industry calls CRDM and nobody who's outside of the industry knows what that means. But CRDM is continuous release detection method. Could you guys go over what those two things are and how STI defines those two and how they sort of impact the category of the tank?

Craig Fletcher: 31:26

So, basically, these are two very important concepts in the SP-001 tank categorization scheme and the tank categories are set up based on risk, and it has to do with the presence of these two different, these two concepts, including spill control and CRDM. So spill control is a way to prevent a release of liquid to the environment, including adjoining property and waterways, and this is your typical secondary containment, whether it's a secondary containment dike or it's a double-walled AST or it's an open-top steel dike or a tank that maybe has remote impounding, which is kind of a term that comes a little bit out of the fire code, but that would be like a large tank farm. So that's really a very important consideration. The other one, as you mentioned, shannon, is the CRDM continuous release detection method and that's a way to detect a release of liquid through the inherent design of the tank system. Now it's considered passive because it doesn't require sensors or power to operate and releases are just detected by facility operators. Now, having said that, it doesn't require sensors or power to operate and releases are just detected by facility operators. Now, having said that it doesn't require sensors or power to operate does not mean you could put a sensor. You cannot put a sensor in there, that's even better. But the way that the continuous release detection method types are one is what we call a release prevention barrier, and that's a barrier that exists beneath the tank that would, in the event of an actual release, that release would migrate to the perimeter of the tank and be detected by operators. An example of that might be a liner under a tank or even, in some cases, a good quality concrete pad that's not cracked and totally damaged. That's another type of release prevention barrier. Another type of CRDM is a double-walled AST with a means to check the interstitial space, or a double-bottom AST Same thing. Another CRDM is an elevated AST. That's kind of another type that's out there. So those are the two key concepts in that.

Craig Fletcher: 33:26

So, getting back to the risk categorization scheme, what we consider is Category 1 tanks have both spill control, secondary containment and the continuous release detection method. Category 2 tanks have the spill control but they don't have a continuous release detection method. And Category 3 tanks don't have spill control. And so tanks, when they grow up, they don't want to be Category 1 tanks, they don't really want control. And so tanks, when they grow up, they want to be category one tanks. They don't really want to be category three tanks. Category three tanks are kind of like the tank out in the weeds. Now under the SPCC program you're required under that regulation to have secondary containment for your bulk storage containers. But there are instances where category three tanks actually exist not particularly common, but the idea being that with this risk categorization along with the tank size, we're able to categorize these tanks and kind of make the determination as to when this certified inspection is to be conducted. So tanks that are riskier tanks, like a Category 2 or Category 3 tank, often has more inspections from a certified inspector and in some cases leak testing that's required than say, a Category 1 tank. So hopefully that gives you a little bit of window into that. I can talk a little bit more too about this breakdown in terms of where this kind of comes up Maybe this will be helpful for your listeners is that tanks 5,000 gallons or less that are Category 1 tanks would typically not ever have a need for having a certified inspection done under the SP-001 standard.

Craig Fletcher: 35:08

So these are kind of relatively small, lower-risk tanks. But once we're at 5,001 gallons, up to 75,000 gallons and you're a Category 1 tank, you're going to need to have a certified inspection conducted by a qualified individual about once every 20 years, which isn't really that burdensome, but that kind of gives you the idea that burdensome, but that kind of gives you the idea. However, if we were looking at, say, a 25,000-gallon tank that was a Category 3 tank. You may need to have that certified inspection done every five years and a leak test and do an internal inspection every 10 years. So we do both external inspections where we're just looking at the outside of the tank. We also do internal inspections where we actually have to have the tank cleaned and actually go into the tank. So what that shows is a penalization of these riskier tank categories.

Shannon Oelkers: 35:59

Compliance through pain points. If you don't meet category one, then you have to do all these expensive things that are very difficult to do, that are very difficult to do. So just to summarize, we see home heating oil tank or office heating oil tanks as our most common category three where if it was a residence it wouldn't be regulated the way it is for a commercial property. And so they have a 500 gallon heating oil tank at the back of the shop but there's no secondary containment. It's single walled and it's smaller, but it still meets the requirement for category three.

Shannon Oelkers: 36:30

But what I want our listeners to understand from what, craig, you just said is that if you've got a Category 3 tank, you can make improvements to it to make it a Category 1 tank by installing a secondary containment area and some kind of release prevention barrier. Or you could upgrade that heating oil tank that's a single wall to a double wall, make sure you have some overfill protection on that tank and then, however you want to do it, replace the tank or add things to the existing tank to bring it up in category. We also sometimes see a category one tank downgraded to a category two tank because something like the secondary containment has degraded over time and it's no longer functioning the way it's supposed to, and you could bring it back up to Category 1 just by repairing your secondary containment. Does that sound accurate?

Craig Fletcher: 37:13

Yeah, the thing that you should keep in mind is that the role that spill control plays in this. Tanks without adequate spill control are, by definition, category 3 tanks. That's the critical thing. So you certainly do not want to fall in that category. The CRDM kind of blurs things a little bit. But when I think about a Category 2 tank, an example might be in an oil field where you've constructed a well and you have some tankage there and you've put in a line area that's got gravel, maybe four or five feet of gravel on top of it, and you've put a tank above there. Now you will have spill control because you've already got a liner and berm system around it. However, you may not have a CRDM because that release from the tank. You could have it go into that gravel and you would never know it unless you had some way to detect it. So that's a good example of a Category 2 tank, but there's other ones out there as well.

Shannon Oelkers: 38:06

Okay, so I will take my summary and back it up and say you could have a Category 1 tank that has degraded to a Category 3 because the containment has degraded. I will back that up. No, problem.

Joe Mentzer: 38:16

Go ahead, joe. Some of the categories also have to do a little bit with history and how tank systems were built, because there's a lot of facilities down in the Midwest that are built on top of clay liners. They're built on top of clay liners and if you have a tank sitting on the ground and it starts to leak underneath, you can't detect that release quickly. It probably won't get far because, hey, the clay around here is pretty good, but if it's sitting on the dirt I may not be able to see it. On the other hand, that same tank elevated in that same clay liner, if it's elevated above the soil and I can see underneath it, well, I'd see the release. That's a category one tank or it's within a containment.

Joe Mentzer: 38:53

I did work at, for instance, fuel terminals where it's built in a clay liner. If I put the tank on the ground, it's category two If I put it on a good concrete pad so that I could see the leak leaking off into the clay. Now I'm a category one, but historically the oil companies and such would utilize earthen containments and some of them were pretty good. So the category two gives a little bit of credit towards that. I mean that's history.

Shannon Oelkers: 39:20

Okay, that makes sense.

Joe Mentzer: 39:21

Yeah, I did some fuel terminals built in the 50s and they had clay liners.

Shannon Oelkers: 39:26

And in Alaska we have quite a few tanks that were constructed in the 19-teens to 1950s. That are just the tanks are literally laying on the ground. That's just how they built them. They would compact a foundation and put the tank on it and then liners came later. But those tanks are typically API tanks not UL.

Shannon Oelkers: 39:43

Okay. So under the certified inspection category there are three categories of tank and if you can get to category one and you've got a larger tank, your inspection burden is going to be lower because you've made all these improvements that have lowered the risk for that tank. For tanks under 5,000 gallons you may not need a certified inspector at all, but you do need to have somebody with your SPCC determine the tank category and the inspection type and frequency as part of your SPCC, Because a smaller tank may if it's a Category 3 tank may have some other additional requirements and I feel like people don't take advantage of that SPCC delineation as much as they should. Your SPCC should absolutely call out the inspection interval. It shouldn't just say STI applies and then leave you hanging as to what it should, tank by tank. It should go down that list and say tank five is due for an inspection or is not, or is a category one or category two, and it should lay it all out there. Best engineering practice.

Craig Fletcher: 40:45

One other thing to add to that, shannon real quick. One other thing to add to that, shannon real quick and this is also available from STIs and we talked a little bit about this during the most recent discussion for SP-001, is that there's a document known as the AST record in the SP-001 standard. Yes, it's in the back and I would encourage those that are. That's something that's a requirement of the owner to fill out and that actually documents a lot of valuable information for the owner.

Craig Fletcher: 41:13

Now, in some cases this may be something with some firms. They might fill that out as part of an SPCC plan preparation that goes through and actually documents what the tank category is and provides a lot of valuable information. And for those that are listening that might be responsible for tank farms or a fleet of tanks, that's another good way to use that information to be able to develop almost like a matrix, if you will, of your tanks and when they might be due for inspections. Of course, that information should be in your SPCC plan, but regardless, epa was very interested in enhancing the use of that AST record as making that more widespread. It's a very good document and it is available for free at the STI website along with the inspection checklist, so that's available for people as well.

Shannon Oelkers: 42:01

We recommend people do the AST record when they get a tank installed as well, because oftentimes some of the data that they have at installation gets lost over time and that. Ast record can capture it yeah.

Joe Mentzer: 42:12

Sure, as someone who wrote SPCC plans, you have to be very thorough and very careful in documenting everything and putting all of the information. There's something called Waller's rule and it says you never make a regulator think.

Joe Mentzer: 42:27

Don't make them wonder what's the inspection cycle? When was this tank put in? What kind of tank? No, no, no. Make it perfectly clear. The SPCC planar should make it perfectly clear. It's this type of tank. It was installed at this date. It was last inspected on this date. Here's the cycle, because once they start asking questions and they dig things up and so make it perfectly clear as to what is required and that AST record, the EPA was involved and they're always involved in SP-001. In fact, it was Mark Howard at the EPA that dreamed up, said the Steel Tank Institute should create a standard for their shop-built tanks, because API 653 wasn't the right standard for shop-built tanks, and so I consider him the godfather of the SP-001 program. But he said that he wants to see an AST record for every tank in an SPCC plant. So I guess that would be good advice.

Shannon Oelkers: 43:25

Well and, as you both know, there's a wide range of complexity. You know the SPCC product. Depending on who is doing the work for you, you can get a wide range of outcomes. And so what I'd like most of our listeners who probably don't write their own SPCCs, but they can certainly grab their SPCC that does not have a specific inspection schedule listing the class of their tank and when the inspections should occur and what type of inspections they probably need to consider that in their next RFP when they ask for someone to do the SPCC, they want to make sure that that's included in that product for them. Okay, so we've covered tank categories, certified inspection intervals. Let's talk about being a tank owner and you've received a report from a certified inspector. What should you pay most attention to in that report? You've got a tank that's over 5,000 gallons in size. It's been 20 years. It's time for that certified inspector report. They come and do the inspection. When you get that report back, what are you looking for? What's the high priority items in there?

Craig Fletcher: 44:28

I can probably address this one, joe, because we do run into this a lot. I mean, just like Alaska, california has its own above-ground petroleum storage act, its own program. So this concept of having these certified inspection reports is not new. It's been in place for over 10 years, so they are more commonly found. This is becoming more and more important for owners because these are typically reviewed as part of an SPCC inspection by EPA and if you have your state organization as well, so this is pretty common to have them review those reports.

Craig Fletcher: 45:05

One of the main things, the main takeaways about this, is that if there are findings in your report and in an SP-001 report, we'll typically have required actions. Those are the ones that the facility owner needs to take to conform to the standard. We also typically have recommended actions, and those are also valuable, but those are ones that we may be thinking more about asset life or other types of things to ensure a safe and compliant operation. But what we're doing with certified inspection reports is determining if these tanks are suitable for continued service. So, getting back to the issue of the required actions and this is something that owners should consider very carefully is that some of these examples of these include tank that does not have, that has inadequate emergency relief venting that's considered a safety issue. Tanks that show visible signs of leaking from the tank or anything connected to the tank that can't be resolved without taking the tank out of service, or damaged or non-conforming electrical systems in hazardous areas that pose an imminent ignition source. Now there are other considerations in certified inspections where we have criteria in the standard where we're talking about minimum steel thicknesses and these minimum steel thicknesses actually go back to the tank category, not to get too deep into the weeds on this. But there are cases where we have, if minimum steel thicknesses are not maintained consistent with the standard, they are required to either repair or replace the tank.

Craig Fletcher: 46:42

So those are required action, like I said, recommended actions. Those are the ones that are primarily for asset management and other good practices. What we've seen a lot now is having agencies closely review these inspection reports and making sure that owners are getting good quality reports goes a long way, because both Joe and I occasionally get calls from California regulators saying Joe and I occasionally get calls from California regulators saying, hey, this person decertified inspection but it's not meeting the standard requirements as spelled out in SP-001. So that's kind of the tricky part. That's one consideration. Back to the owners, if the inspector report says there are some required actions to be done and the owner does not implement those required actions, the owner could be at risk for not essentially implementing their SPCC plan, and I've seen EPA and other agencies use this provision during enforcement proceedings. So that's something very important for owners to be aware of that. Once it's brought up there, it's part of your compliance program.

Shannon Oelkers: 47:55

What's the timeline under the SPCC? Because we definitely have our clients and listeners. Once you've identified a problem, how long does the SPCC give you to fix it?

Craig Fletcher: 48:04

The SPCC itself would give you a certain number of months to update your plan. However, I think the concept there's kind of a practical level to this. If your tank is leaking product, I think that's a short interval right as soon as possible. Yeah, I think the agencies too would also take a look at if is an owner making progress toward getting things done. So that's an enforcement matter that I can't really speak on because I'm not a regulatory agency, but I know from experience of working with them that it goes a long way in trying to show some diligence for sure.

Shannon Oelkers: 48:42

The takeaway, though, is you can't receive the report and do nothing. You need to look at the required stuff and determine if something needs to be immediately taken action Like I've got a leaking tank I didn't know about and then you also need to look at all the other required pieces and start having a plan for getting them corrected as soon as you can, and then have that plan in place. Even if you can't do it right all right away, at least if a regulator shows up, you can say we've identified the problem, we're working on a solution and we've got a plan forward. You can say we've identified the problem, we're working on a solution and we've got a plan forward.

Joe Mentzer: 49:09

Often I've seen where the regulator wants a schedule. If you have a good report that's clear on what they found and what needs to be done, that's a good start, okay, and now let's look at what needs to be done. And well, here I'm planning on doing this. Here's my schedule, because sometimes I've done it, where we've inspected the tank, it's got a couple of modest issues. You know what? I'm going to replace that tank. So I'm going to do these few minor things and in eight months I'm going to have a brand new tank, because I wanted a bigger tank anyway, or something like that. So, if you have a clear schedule but bear in mind, they're going to hold you to it. If you have a good history and you've always followed up before, yeah, they're going to cut you a little slack. If you've told them things that ended up not being true in the past, they're going to be all over you.

Shannon Oelkers: 49:53

Yes, the relationship with the regulator is super important.

Joe Mentzer: 49:56

It is good that a report should have a clear conclusion, a clear statement Is this tank suitable for continued use? Because, as Craig pointed out, if you have an immediate problem, the SB-001 says, well, shut the tank down and fix it now, don't wait. So it's kind of how bad is the problem? What are the circumstances? You know, I got to paint my tank, but it's late November. That's not going to happen for a while. But have a plan, have a schedule. That's what the regulator wants, because they're going to go after the people that are doing anything.

Shannon Oelkers: 50:43

They're not going to go after the people that are doing anything. They're not going to go too hard after the1 that address finding and removing water intakes, and all three of us in this interview. I would like to have you guys talk a little bit about water and why it's such a big part of the STI SP-001 for our listeners. So why is it so important? Why do we address water specifically at the monthly, the annual and in certified inspections?

Joe Mentzer: 51:08

Carbon steel is a great material to work with. It has flexibility, it can be welded, it can be formed, it's very durable, but it rusts when it's exposed to water. So water is the enemy. We have a kind of a statement at STI that if you have a properly built and operated tank, if you keep clean product in the tank and paint on the outside, its operational life is indefinite. But let junk build up around the perimeter and hold water against it or let water sit in the tank, you could be gone in 18 months.

Joe Mentzer: 51:43

Some of these smaller tanks that are thinner, so the presence of water will greatly affect, are thinner. So you know, the presence of water will greatly affect the predictability and the reliability of your system and we want you to have a reliable, predictable system. And then we also have the issue with microbial growth, which is just gets more interesting with some of the new fuels out there. But it really can't happen without some water. So keeping your fuel clean and dry helps prevent microbial growth. And something I've noticed is we have a lot more tanks that get filled up and they just sit with product. You know those generator-based tanks, those backup. If you have a constant turnover of fuel, that will address some water issues.

Joe Mentzer: 52:27

But if you have a tank that just sits well, now you've got a collection point, but, yeah, water in a tank, it is going to adversely affect the tank from the inside. Or if you let water and junk build up on the outside, it'll adversely affect Just water and carbon steel not the best friends. That's kind of the end thing. And then it can mess up your fuel. But bear in mind, in the SPO and standard, I'm not taking care of your fuel, I'm taking care of your tank. So, as long as your fuel isn't attacking the tank, if you're really counting on that fuel in a tight spot, you want to be inspecting it even more often, because I have seen tanks where the tank was okay but the fuel inside the tank wasn't worth it. And when they you know, remember an airport I worked at they had a power outage. Out of seven generators, one started, four or five of them were frozen solid, one was out of fuel. But still, here you are, finally need it and nothing. Yeah, so yeah.

Shannon Oelkers: 53:28

Could you guys talk about microbial infection, if you will, Because once microbial corrosion occurs it's pretty difficult to get out of a tank. Is that correct?

Joe Mentzer: 53:39

That depends on the tank and the product being stored. There are some things going on. I mean the issue of water. Some of the new fuel blends don't have certain things that were in the older fuel blends, sulfur being one of them. It helped keep some of the microbes in check.

Joe Mentzer: 53:54

Some of the biodiesel products, which maybe you don't use so much way up in the north, but those add some things. The other one is and this happens in the process where fuel is transferred and moved around you can get traces of ethanol in, like fuel oil, just because it was in the same truck that held. Well, ethanol is bug superfood and so you get a little just. There's a great report the state of Georgia did the guy's name is David Howell, he did a report on this and just traces of ethanol and traces of water create circumstances that you wouldn't expect to occur, but just can, and all of a sudden bugs start growing. But yeah, another thing to bear in mind is, once you identify microbial corrosion, well, now your fuel's compromised and you got to be careful what you do to the fuel, because you don't want to add anything that's going to make the fuel now be a problem for the user.

Joe Mentzer: 54:48

When I ran into it. I always got my fuel supplier involved and say here's my problem, what do I do? The fuel is warranted by the manufacturer and if I start dumping things into the tank, there goes my warranty If my additive screws up my customer's fuel injection system. So be careful, what you add to your tanks, you know, got to get rid of the water Absolutely. Maybe you need an additive, depending upon how much fuel you have. Maybe you empty the tank and start over again, but bigger ones maybe you can't do that. You have to kind of address it based on your circumstances, but you have absolutely positively have to address it. And some industries a little like the aviation industry, they go nuts on water Daily water draws for every tank.

Joe Mentzer: 55:34

You laundered a few jets into people's backyards. You get noticed, you know.

Shannon Oelkers: 55:39

But that's the risk factor. Right For aviation, it's a high risk situation.

Craig Fletcher: 55:43

So they've upped it.

Joe Mentzer: 55:44

So, yeah, water check regularly, check, often, maintain the equipment, the places on top of your tank, because when I find people with a water problem, we say, well, where is it coming from? You know, emergency vent, some other fitting, maybe the roof's draining. When it's raining it's landing on top of the tank and you know, because the stuff's usually weatherproof, but you deluge it enough, you can overcome it. So find the the source too. But yeah, definitely don't ignore water. It'll bite you in the backside and it'll do it at the worst possible time.

Shannon Oelkers: 56:17

And it deteriorates your acid. If you just leave it and leave it and leave it, it's just going to continue at it. So, just like a fire, for microbial infection or microbial corrosion to occur, you have to have steel, fuel and water, because those three together have all the right pieces for the bacteria to thrive or the microbes to thrive. One other thing to add to that.

Craig Fletcher: 56:34

Shannon, is when we run into clients or facilities that have concerns about water and tanks. One thing that is done widely at least in the lower 40, probably also up in Alaska is doing fuel polishing and having someone come in and polish the fuel and that's a good time to. You can certainly also have more formalized ASTM testing done of your fuel to determine if including some of the microbial side as well, Potentially using biocides as well, is another one, because these microbes are ubiquitous, so it's just not like it only takes parts per million of these microbes to be able to get you going. But trying to kind of have a good program for fuel quality is something important, particularly for critical sites, whether it's a data center or a hospital or an airport or whatever.

Joe Mentzer: 57:27

We do have a recommended practice on keeping water out of the tank. I think it's R111.

Shannon Oelkers: 57:33

We will make sure to put that in our show notes. Yeah, water management is pretty important, and I think, craig, your point about how critical this fuel being functional is is well taken, because a lot of our clients have emergency generators. They have their own fuel tanks. That they're like. We have a lot of fish processors. They're making their own power four or five months of the year, but then the other six the tank is just sitting, and so having water management occur throughout will just help preserve your asset of the tank but it'll also help preserve your six to $7 a gallon diesel asset as well.

Shannon Oelkers: 58:09

So one last like serious question because I have a lightning round plan for you guys up next, but this is something we get a question quite a bit from our owners is does an STI SP001 inspection need to be performed at tank installation? Because there's one due every 20 years but the regulation isn't super clear about. Does it need to be done at the beginning as well? Does it need to be a kickoff inspection or is it just once the tank's installed? Then 20 years.

Joe Mentzer: 58:38

No, it does not need to be done.

Shannon Oelkers: 58:39

Do you want me to take?

Joe Mentzer: 58:40

this one, joe. In fact the SBO1 standard says that before an inspection should be done. It's one of the early items. It's in Section 1. I think it's 1. Let me even look that one up for you because it's an important one and there is some confusion. I have done commissioning inspections.

Joe Mentzer: 59:00

1.2.4 says the owner is responsible for making sure that the system is designed and installed properly. You know SP-001 is trying to assumes that the system is properly installed and is trying to identify degradation due to time, use, exposure and the other thing too, because of all the wide range of systems that can be, this can apply to an installation inspection. You know it has to make sure that all the components that are installed are installed per manufacturer's recommendations. The storage tank which our members built, that comes our STI storage tanks come with document R912 on installation instructions on how to properly, you know, make sure the tank is on a good foundation, confirm the integrity of the primary and secondary tank at the time of installation. You know, make sure everything is in order with the new tank before the first drop of fuel hits it.

Joe Mentzer: 59:54

But you have piping components installation. You got to make sure you got all your setbacks in order. Are you far enough Because it's a lot easier to do it now than later, so those sorts of things. So an SP-001 inspection it first starts at the end of the first month with the first monthly inspection. Certainly any brand new tank system should pass the basic SPO and inspection with flying colors. But you really don't need to be using an ultrasonic thickness tester on a brand new tank because two or three people have already done it before you.

Craig Fletcher: 1:00:24

Yes.

Joe Mentzer: 1:00:25

Yeah so.

Craig Fletcher: 1:00:26

I can tack on that a little bit too, shannon is that we run into this issue as inspectors getting requests for doing certified inspections for initial commissioning, and I think part of the reason is several fold. But the standard itself what triggers that 20-year inspection date, if you will, is the initial service date. That's the date and when product first hits that tank. So that's our clock start, if you will. And it doesn't matter if the tank was used somewhere else and then brought to a new site. The initial service date is when that tank first had product, even if it was at another site. So that's how that 20-year cycle, or whatever the frequency is, starts. But getting back to the issue that we run into with people asking for certified inspections upon initial commissioning, I think it goes back to a couple different things. One some owners want peace of mind that the contractor has actually installed the system consistent with fire codes and other things.

Craig Fletcher: 1:01:23

Some states, including California, don't have a statewide installation permit program for ASTs. That's kind of left to the local jurisdictions. But really the standard wasn't developed with that in mind. But I can see why people would actually request it and it can be a contractual thing. We've got some federal agencies asking for this as part of that, and it's probably because they've been burned in the past by having stuff that got installed improperly that they find out later. We're also aware that insurance companies are calling for certified inspections of tanks and that's probably a risk reduction type approach. So it may be more of a peace of mind thing as opposed to and that's probably a risk reduction type approach. So it may be more of a peace of mind thing as opposed to something that's mandated in the standard. The beauty of this SP-001 is it extends out beyond the tank so we get a chance to take a look at stuff like venting and anti-siphon issues and other things like that. But there is no hard and fast initial certified inspection and install required.

Shannon Oelkers: 1:02:21

Yeah, we have definitely been seeing an increase in requests for it.

Shannon Oelkers: 1:02:24

I also have seen they want a document that says the next inspection date on it that they can refer back to for their databases or their tank inspection matrix, because they're managing hundreds of tanks, right, sure?

Shannon Oelkers: 1:02:38

And when you have it installed by a contractor you're not necessarily. You might get a job book but you don't get a cover sheet that says this tank was installed on this date. It's a class one tank and it should be inspected in 20 years. They're saying they met the installation standard, but they're not necessarily projecting out that inspection date. So I've definitely seen that come across. In addition to what you said, craig, as far as peace of mind, especially with the DOD, we've had a lot more requests from the DOD to do some kind of initial, especially for tanks that maybe are older, like maybe 10 or 15 years, and they're moving them from one place to another. They want to make sure the tank is good to go with the UT thickness and everything else, even though it's not necessarily time for it, because they just want to make sure before that they put it into service everything's good.

Joe Mentzer: 1:03:20

I certainly did lots of inspections of tanks that my clients own and were relocating and before they moved them, hey, let's make sure that we need to relocate this to a new spot and not to the scrapyard and that's definitely a good. But, yeah, on brand new system, I work in a state that has a commissioning process that has several inspections and a long litany of tests that we do prior to the first drop of fuel hitting them, and they're much different than SP-001. And so, as far as commissioning goes, I would recommend more steps on a commissioning process than are listed in the SP-001 standard. There's a lot more, yeah.

Shannon Oelkers: 1:04:02

Alaska and the state of Washington. I do not believe. I don't think the state of Washington has a commissioning process. I know Alaska does not. It's just the Wild West up here.

Joe Mentzer: 1:04:12

And, as you said previously too, you want to make sure you capture certain information at the time of startup, because the further you get away from startup, the harder it is to track that stuff down.

Shannon Oelkers: 1:04:22

And that was part of our commissioning process was putting together all of the records and handing them to the owner, so that, ok, now, in five years, when someone asks here's all this stuff to have that information in it too, because oftentimes job books are just a collection of really badly scanned weld seam reports and liner installation reports and we're encouraging them to include an AST record and an installation verification sign off by an engineer or somebody knowledgeable, up to and including a certified inspector, just something to make that record usable in the long run for the life of that team.

Shannon Oelkers: 1:05:05

Okay, so those were all of my questions that I had for you that were sort of more in depth. If you guys are up for it, I have a lightning round of just things we find on the monthly and annual that we get questions about a lot that I would dearly love some clarification on. The first one is cracks in concrete foundations or containment walls. And maybe because we're in Alaska, we see, you know we have earthquakes and we have harsh environments, but is it any crack whatsoever or is there some leeway for minor small cracks? I mean, like, where do we fall on? Are there cracks in your concrete foundation or concrete containment?

Craig Fletcher: 1:05:37

I can try and address this one, because we do talk about it in the STI class, but the standard itself is silent on that issue to my knowledge, and this issue should really be addressed by the SPCC plan writer. This kind of falls back into their world and so they're the ones making the call as to remember that under the SPCC regulation the containment is required to be sufficiently impervious to contain discharged oil until it can be cleaned up. Having said all that, I can give you some general guidance, not from the SP001 standard, but just some general concepts out there. But just remember that concrete by its very nature is going to have some cracks at a microscopic level. That's just how it works, right. But it doesn't mean it's not suitable for containment. But remember that containment needs to be constructed to good engineering practice. So that means if we're putting in concrete it's going to reinforce concrete. It's not just going to be hollow block masonry walls. We see a lot of masonry walls with grout failures that need to be addressed. So there are provisions under NFPA 30 for containment to be solid masonry, not just hollow masonry walls, if that's what's to be used. So that's a separate fire code matter. But we run into that a lot and that's almost destined to fail. So that means that you're going to typically have rebar and mortar inside of the actual hollow blocks if that's what you're deciding to do. Just some other general guidance.

Craig Fletcher: 1:07:07

Like I said, this is not part of SP-001. But if your containment is not holding water consistently, it's probably not going to hold oil. I mean not to be Captain Obvious about it, but you know that's sort of the basic. Another one is if you have cracks and you have vegetation growing up through the cracks, that also seems like it's not going to really pass the laugh test, gotcha, and then other ones that we think about, if on our company side, is that if you've got cracks that show lateral or vertical offsets that imply structural problems where you're having failing, maybe due to subsidence or frost, heave or other things, those need to be addressed by the plan writer.

Craig Fletcher: 1:07:52

Overall, hairline cracks don't usually cause problems, but those should be monitored. Where we start kind of drawing the line a little bit is somewhere between maybe the thickness of a credit card to a sixteenth of an inch, which is about the thickness of a quarter. Those should be addressed, those that are getting up to that, the thickness of a quarter, which, like I say, is about a sixteenth of an inch. Those are definitely worthwhile to be looked at. Those should be monitored and, as needed, addressed by the SPCC plan writer. Just remember, they do make crack gauges out there that are relatively cheap that facilities can use to track whether they're actually having an issue or not, whether your cracks are growing. That's just some general guidance.

Shannon Oelkers: 1:08:37

It's not part of SP001, but it's just a thought it does come up a lot when we do the training for monthly and annuals, though, the guys are like well, we have cracks and I was like well, yes, but they need to be bad cracks, Then how do you tell? But I like the tools that you gave us.

Joe Mentzer: 1:08:54

I'll add two things. First off, when building there are standards. The American Concrete Council, I think I can get you the reference. There is a standard for construction of containments for hazardous materials. That one should certainly be considered. A lot of the concrete guys I worked with would incorporate mesh into the top of the concrete. It's just below the upper surface. That helped minimize cracks, or at least in the Midwest we say there's two kinds of concrete Concrete that has cracked or concrete that will crack. And the last one is if you have to look at the crack inside, gee, is it leaking or not? You probably would go back to Waller's rule Don't make them think, just get out. You know, seal them up. It's easier that way.

Shannon Oelkers: 1:09:33

Seek a flex for everybody. Seek a flex, all right. Second, lightning round. A lot of our tanks, you know they've lived a little. They have dents or creases or other kinds of like stable marks on the shell. They got kissed by a loader right before installation. You know something happened. How do you address those in the periodic inspections? Cause there is, there is a question that says are there any on the tank? But some of these are stable and have been with the tank for years. They don't affect the integrity. How do you handle?

Shannon Oelkers: 1:10:03

that under the STI inspection.

Craig Fletcher: 1:10:06

Well, normally, in those cases when we often see denting, for example, that in our experience, appears to be often associated more with venting problems and venting insufficiency. Why is it there? Yeah, tanks can't take vacuum. They cannot withstand very much vacuum, and so that's really why you will occasionally see denting on tanks. Now, if somebody ran into it with a loader, that's kind of a different matter, but what we typically do is to try to monitor those areas and maybe mark off where that dent is to see if it's actually changing. However, if there are severe cases where denting is occurring, that's where you're going to probably need to have a tank engineer involved to be able to really look at that further. For minor denting, it's probably something you should just be monitoring during your monthly inspection.

Joe Mentzer: 1:10:56

You got to figure out. Why is the dent there? I've seen some dents. Why is that? Oh, because it didn't make it under the bridge when it was on the back of the transport truck. Yeah, that's a bigger problem You're going to be looking at. Did you take the carbon steel past its plastic limit and start to deform it, stretch it, thin it, crack it? Or is it just where carbon steel can flex in and out a little bit? Like Craig said, at some point, you need a tank engineer and you really need to know why is it there.

Shannon Oelkers: 1:11:23

I think for the purposes of this. We all know why it's there. It's been there since the tank was installed. The tank is 15 years old, it's never changed and maybe you guys can tell me. What I have advised in the past is you know how you can take the monthly or the annual and you can enter in text in the comments. I would just enter the you know crease on west shellhead or whatever, 18 inches long, stable or something. So you are acknowledging that it's there, but it's not something that appeared prior to the last month and that makes you want to look and see if there's a venting problem. If we know it's there and it's stable, just indicate it, put it permanently into the inspection record for that tank and then you can just keep checking off. Yes, it's fine, you don't have to keep writing it in every month or every year.

Joe Mentzer: 1:12:08

And when I ran into those informal inspections I was looking for if the steel thinned or if there was a hard crease in the tank, those sorts of things, and those would catch more of my attention in the tank, those sorts of things, and those would catch more of my attention, gotcha?

Shannon Oelkers: 1:12:25

Okay, cool. Let's talk about tank grounding. We get this argument quite a bit. If there's no grounding strap on your standard UL 142 constructed tank, could the tank still be grounded? And how do you know?

Craig Fletcher: 1:12:35

So that's kind of a question that's a pretty site-specific one that may actually require an evaluation by a grounding expert or an electrical expert. Now, if a tank's located on a concrete pad that's not directly in contact with the earth, it's unlikely that you would probably have direct connection. You could claim the tank was grounded. Have direct connection. You could claim the tank was grounded. Remember that for grounding and bonding, what we're trying to do, there is dissipation of static charges that develop during fuel transfers and it's particularly critical for jet fuels and other similar non-conductive liquids. There is also a school of thought that some of the grounding and bonding does provide some lightning protection, but that's kind of a separate whole specialty so I don't really can offer any opinion on that. But some folks say that tanks located directly on the ground itself may be grounded. But I think that's something that you probably have to prove out somehow through conductivity testing or some other way to do that or getting an expert in that field involved. That's the best.

Shannon Oelkers: 1:13:42

Or grounded the normal way. So compliance through pain points yes, yeah.

Craig Fletcher: 1:13:48

It's not rocket science to do grounded.

Shannon Oelkers: 1:13:51

We get a lot of it's grounded. It's grounded and I'm like, but for me to check this off as the certified inspector, I need to know it's grounded and I can't tell right now. We get a lot of the pipings grounded and it's connected to the piping, which may or may not be true as well. Joe, do you have any thoughts on this one?

Joe Mentzer: 1:14:07

Well, that goes back to that Waller's rule thing. If grounding is required, it should be obvious. There are points, normally on smaller tanks you can tie in. There's usually a lift lug on the tank and tie in. There's usually a lift lug on the tank and that's a good place to either put a you know, either a clamp to the lift lug or drill a quarter inch hole and attach a ground strap there. Certain tanks don't need grounding. Certain chemicals they don't recommend grounding, although petroleum it generally is. But in my mind it was always. It should be pretty obvious that there is a ground strap there, because if there wasn't, then the only way to convince the inspector was to have an electrician confirm it's grounded. And then next time, well, can you confirm it again? It's like just put the ground strap on and make it blatantly obvious that it is grounded, path of least resistance.

Shannon Oelkers: 1:14:53

Yep, we also see tank grounding straps that get caught by snow plows and stuff quite a bit because they're under. So I've seen grounding straps that when I pull them up they just come out of the leaf litter. They've been severed at some point. Surprise, okay, thank you for that. Visible signs of coding failure. As you know, I work you know, pacific, northwest alaska we have a little more severe environment than other places. What would you consider to be coding failure that needs to be documented on the periodic forms, like when do we get there? Where does STI or common sense say that we should do it? Because a lot of our tanks they almost all of them have coding failure in some way. I'll be honest.

Shannon Oelkers: 1:15:32

So, when do we get to the point where we would start monitoring it and documenting it?

Craig Fletcher: 1:15:35

Well, I think the key thing with that, shannon, is that the definition of coating failure in SP-001 is significant peeling, cracking, spalling, pitting of the coating paint or lining on an AST resulting in the exposure of the metal surface and corrosion of the tank shell. So you can lose your. Maybe you have a primer coat. You may have a paint coat on top of that. You could theoretically lose the paint coat but still have the primer coat underneath, which would not be under this definition of coating failure. However, at the point you're basically having, you're seeing rust on the tank.

Craig Fletcher: 1:16:12

That's the time that where coating failure is defined, that under the standard Okay, is defined under the standard. So when we do a formal inspection right, a certified inspection we really evaluate that, because what we're doing there is we're using tools ultrasonic thickness testing to quantify the remaining steel thickness of the tank. So that's really it may look bad, but it may be somewhat trivial in terms of the actual integrity of the tank itself. However, that definition of coating failure is in the standards, so that kind of speaks for itself in that regard. Remember too that it's usually a lot more cost-effective to address coating failures in spot locations than it is to go in and completely redo a tank, which is a long, involved process to do it right for a complete tank coating replacement.

Joe Mentzer: 1:17:05

And when I'm doing an inspection I really got to. The first thing people see when they walk up to a tank is the paint. I've installed lots of brand-new tanks and it gets delivered and the first thing the guy who bought it oh, how's the paint look. So, any minor blemish on the paint? I almost have to put it in the inspection report because my customer is going to see it and if I don't write it down, well, what does that inspector know? He didn't see this in air quotes obvious issue. So yeah, paint tends to get brought out. A lot Paint.

Joe Mentzer: 1:17:32

The coatings industry has advanced a lot in the last several years and those guys will tell you that when you start to see some rust, it just means that the paint in general is coming to the end of its life. So bear that in mind. Unless there's some physical damage to it and Craig hit the nail on the head take care of those minor issues quickly with just a little bit of cleanup and a coat of paint and then we won't call them out. But yeah, you can't ignore rust too much.

Shannon Oelkers: 1:18:00

No, no, I think it's just the reality of Alaska is the environment's harsh. So coating failure is just something that we have and it's got to be. But what I want our listeners to understand is that you should be monitoring it and documenting it in the monthlies and annuals, because that gives your certified inspector clues to how long the problem has been in place, which can affect corrosion rate calculations or suitability for service, like if it just started happening a couple months ago and is advancing greatly. Something's changed about that tank and we need to figure out why, and it may be that the coating has come to the end of its useful life. It may be that something happened to the tank. It may be that the tank has, you know, changed service and something's changed, or it's had an event I don't know something like where they power washed it but it was too high a setting and it damaged it, something like that. Okay, I have one last lightning round question for you.

Shannon Oelkers: 1:18:52

A lot of our tanks that are double walled, they're outside of secondary containment. They have overfill prevention valves installed in line with the fill connection, because that's very efficient when less appurtenance that you need to have. There's a monthly requirement to tell that they're in good working order. How do you do that if you'd have to disassemble the whole tank? And I was always taught not to fill the tank up and pop it right. You're not supposed to fill the tank up and overfill it essentially so that you can tell that it's working. So do you have any tips for how to address that on the monthly for those of us with inline overfill prevention valves like floaters?

Craig Fletcher: 1:19:29

There are a rare few overfill prevention valves like you're describing that actually can be tested externally, and some of these have a cable that can be used to manipulate the float inside the valve. But these are not very common and they're more expensive. But you're right, most overfill prevention valves require complete removal to actually perform, to confirm that they're in good working order, and that is not something that owners even certified inspectors for that matter typically do. This is the work of typically a petroleum contractor or some other mechanical contractor to perform. So not only would they have to remove it, check the float, they're going to have to reassemble it and put it back in and pray that they get the right setting on the tank level so it can work right. So, other than taking a look at the top fittings on the tank where that valve comes into the tank for stuff like damage or corrosion or if it's leaking, there's very little you're going to be able to do with those.

Craig Fletcher: 1:20:32

Having said all that, it's important to remember that overfill prevention valve is your last line of defense when it comes to preventing an overfill. So you should be having gauges and high-level alarms on those tank systems. Those are your first lines of defense. Owners should not be relying solely on an overfill prevention valve as their sole means for overfill prevention. That's kind of the takeaway from that. Normally, I have you know, in some places in California the fire marshal will be there when they do the first fill and they want to see that overfill prevention valve actually operate properly. Sometimes it hasn't been installed properly and there's problems. So overfilling tanks is nothing I ever, you know, intentionally recommend anyone to do, but it is one that's very difficult on these valves that have no means of external checking.

Joe Mentzer: 1:21:23

So I'll add several SGI members manufacture those valves. The regulators I've dealt with have said follow manufacturer's recommendations. So look and see what the manufacturer has, because that's also the club, because that's an appurtenance that gets installed by somebody else on that tank. But those manufacturer instructions are what the club that the regulator is going to beat you with. The component manufacturers have gotten much better now that they recognize that there can be maintenance requirements there Craig pointed out. Yes, there are some that can be tested, so that option exists.

Joe Mentzer: 1:21:56

So you know, make sure you follow manufacturer's recommendations and maybe ask what equipment's being installed and make sure that it's a maintenance schedule you can live with, because some are better. Especially, I see this on generator base tanks. Those units come out. They got the cheapest equipment imaginable, trying to keep the price of the whole overall, and you end up with this junk that ends up being more grief than it's worth in the long run. You end up fighting it and then replacing it at a significantly more expense later with a better component. But manufacturer's recommendations the good manufacturers list them on the internet so you should be able to get yourself a copy. So that way when the regulator asks, yep, here's the recommendations, here's what we do, that is really good advice.

Shannon Oelkers: 1:22:46

Thank you for that. Okay, Does STI SPFA have any free or low cost resources for our listeners, Joe, that want to learn more?

Joe Mentzer: 1:22:55

Oh, certainly we have lots of webinars on very good, very specific tank-related subjects. Our website is wwwstisbfaorg. I mean I did a webinar earlier this year on generator-based tanks. We've got one coming up on tank appurtenances, stuff, on coatings. Some of it's more towards the field-ed stuff, but there's still great information there and our website is also full of information, documents that you can obtain from our bookstore, the installation instructions, how to properly address water, the checklist. There is lots of free information that you can download and look at and there's access to articles on tanks.

Joe Mentzer: 1:23:38

It's hard to find tank information. I mean I had to take salesmen out to lunch when I was first learning this to try to. They were the ones that knew the stuff back in this was the early nineties. They were the ones that knew things that and the installers had to buy them beer. But now it's being documented and put together in some specific places. But yeah, our website's got a lot of good information.

Joe Mentzer: 1:24:03

Certainly the Petroleum Equipment Institute, another organization. They write a lot of standards. If you want to know the standard for how to install an above-ground tank for vehicle fueling, for marina, for backup power, for bulk storage. They have written those cost you money but they are kind of the accepted standard for things on how things get installed. The fire codes have things. Those aren't free but yeah, if you're looking for free, our website's probably as good as you're going to get. But especially when you start to get into some specific applications, you might have to look for those construction standards like the PEI ones as well. And then the manufacturers do it For the stuff attached to the tanks. Morrison Brothers has great information, clay and Bailey has great information. They support their products well. A lot of the other ones that make stuff for tanks they will support their products as well.

Shannon Oelkers: 1:24:57

We use the Morrison Brother tank outlays, with all the appurtenances labeled, to train our employees when they start with us, because it's such a great layout.

Joe Mentzer: 1:25:05

Especially on small tanks. When I would do a tank design, I'd start with that. I got that. I don't have that. Yeah, that's the Morrison guys. They do a great job of supporting the product.

Shannon Oelkers: 1:25:16

They do Well. Gentlemen, thank you so much for coming to Tank Talk today. I really appreciated everything you had to share with us. I have learned so much and our listeners, I am sure, are going to enjoy this so much. Is there anything you want to say before we sign off, any last words?

Joe Mentzer: 1:25:31

Don't hesitate to reach out with questions. I am an industry resource for our members, but I also help people who purchase our members' products. Get them pointed. We answer questions. Let's put it that way. So if you email us a question, we'll get you an answer.

Shannon Oelkers: 1:25:47

Awesome, hi there. This is Shannon Olkers and, as the owner of Integrity Environmental, I wanted to take a minute here at the end of the podcast to make sure that you knew the following 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 arise from the use of 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 that would be me or Integrity Environmental. Thank you very much for listening and if you do need professional regulatory advice, we'd be happy to help you as part of our consulting services.