If you have a SPCC Plan then you know you must complete integrity testing for your tanks. The EPA has spelled this out since the 2002 changes to these regulations. The allowed some grace period to get it completed by November 2011.

If you have above ground storage tanks the professional engineer should have designated a period of time to complete your inspections including the integrity testing of bulk containers larger than a drum. You should make sure your tank has a UL 142 stamped label on the tank. If you do you should be able to have the tank in service for 10 years without integrity testing. If you do not have a UL label or you do not know how long the tank has been in service, you should arrange for this testing immediately. If you know the manufacturer of the tanks you may contact them to verify the date of service or the standard which was used to construct the tank.

The EPA regulation 40 CFR 112.8 states a qualified inspector with either Steel Tank Institute (STI) or American Petroleum Institute (API) complete the inspection. There will be a visual inspection to verify the tank system is complete and one form of non destructive testing. Since technology exists with the ultra sound device, many companies including ours uses this type of device.

The key to not completing an internal inspection is the tank cannot be in contact with soil. The ultrasound measurement device allows us to do this inspection at a reduced rate.

Some basic questions you should be asking your staff.

  1. Do we have an integrity testing program?
  2. Do we have all inspection and maintenance items in our SPCC Plan.
  3. Do we have any plastic totes that we are reusing in service over 5 years.
  4. Do we have any bulk containers greater than 55 gallons that we have had in service over 10 years need integrity testing by a qualified inspector.
  5. Have we completed all items of concern from maintenance items and inspectors requirements.