The United States Environmental Protection Agency's Spill Prevention, Control and Countermeasure (SPCC) Regulation was originally passed in 1974 and recently revised on July 17 2002. SPCC requires facility owner/operators to prepare and implement a plan to prevent any discharge of oil into or upon navigable waters of the United States. Oil is broadly interpreted to include materials that are derived from petroleum, animal fat and vegetable oil. This broad interpretation triggers regulatory compliance by numerous sectors of industry including petroleum refineries, paint manufacturers, specialty chemical producers, and food processors and many others. In addition, navigable waters are defined not only as waterways passable by vessels, but can include streams, wetlands, lakes, and other features such as storm sewers that lead to navigable waters. This wide definition affects numerous facilities that are situated considerable distances from actual waterways. The revised SPCC has new requirements for developing and implementing plans to ensure the integrity of aboveground storage tanks using highly technical test methods.
The latest SPCC revision requires all facility plans to be amended by February 2006 and the implementation of the plans by no later than August 2006. Significant changes were presented in the July 2002 revision including language that strengthened and clarified aboveground tank inspection requirements. Facilities must conduct tank inspections on a regular basis using recognized industry standards and the inspections must combine visual examination with nondestructive testing techniques. Industry standards that are referenced include those produced by the American Petroleum Institute (API), American Society of Non-Destructive Testing (ASNT) and the Steel Tank Institute (STI). Prior to the revisions, inspection requirements could be satisfied with visual examination only.
The various industry standards can be adapted and incorporated into a tank integrity testing program that addresses facility specific conditions. Developing the integrity program involves inventorying tank systems, reviewing tank system design/construction, assessing stored material characteristics among other items. Implementing the program involves training on-site personnel to perform routine inspections and employing a battery of non-destructive test methods. Test methods are selected based on factors determined during the development of the integrity plan (tank construction, age, environment etc) and include hydrostatic, ultrasonic thickness, magnetic flux leakage, etc.
If the tank inspections are performed using good practices that follow industry standards, other benefits beyond complying with SPCC can be recognized. These benefits include capital planning based on actual equipment life expectancy calculations, focused maintenance/repair resource allocation, safety incident prevention and others.
