New AC Tank Inspection Protocol Now in Effect

New guidelines have been established for above ground storage tanks that contain asphalt cement; here’s what you need to know

February 28, 2018

Jessica Lombardo

As a part of the Clean Water Act, the Environmental Protection Agency (EPA) implemented regulations that required any facility with a total bulk container storage capacity of 1,320 gallons or greater to develop and implement a Spill Prevention, Control and Countermeasure (SPCC) Plan.

In 2011, revisions to the regulations included the requirement that all bulk containers, including above ground storage tanks (ASTs), be inspected according to a “national industry standard.”

This change to 40 CFR Part 112.8 (c) (6) requires that the plant owner or operator:

“Test or inspect each aboveground container for integrity on a regular schedule and whenever you make material repairs. You must determine, in accordance with industry standards, the appropriate qualifications for personnel performing tests and inspections, the frequency and type of testing and inspections, which take into account container size, configuration and design…”

This was a very significant change that took effect in November 2011. Given the 5-year cycle of review required for all SPCC Plans, this regulation change meant that all facilities subject to the SPCC Plan regulation needed to address the issue of AST inspection by no later than November 2016.

“Following the November 2011 federal rulemaking, and absent a “national industry standard” for inspection of ASTs storing asphalt cement, asphalt paving production facilities needed to determine on a case-by-case basis the proper inspection protocol for their individual tanks,” Bernard Bigham, principal of the Chesapeake Environmental Group and certified tank inspector says. “This protocol needed to be detailed in the site-specific SPCC Plan and approved by the signing P.E., including the scheduling and parameters of the inspection and the qualifications of the inspectors. This was an added regulatory burden to the asphalt paving production facilities.”

So the National Asphalt Pavement Association (NAPA) looked for a way to help its members comply with this new requirement with their 2014 “Guidance for the Inspection of Aboveground Storage Tanks Containing Asphalt Cement at Asphalt Pavement Production Facilities.”

This Publication addressed many (but not all) of the issues facing the facilities in implementing the requirements of 40 CFR 112.8 (c) (6).

In 2016 the EPA approached both NAPA and Steel Tank Institute/Steel Plate Fabricators Association (STI/SPFA) about modifying STI/SPFA’s SP001 Standard to include liquids that are stored at temperatures greater than 200°F.

STI/SPFA assembled their standards committee, including NAPA representatives and throughout 2017 discussed the modifications necessary to enable SP001 to be used as a viable inspection standard for ASTs containing asphalt cement and other similar thermoplastic liquids.

SP001 & Increased Inspections

Following adoption of revisions to the SP001 Standard early in 2018, the STI/SPFA announced that the new edition of SP001 now includes specific standards for the inspections of tanks storing liquids such as asphalt cement, as well as other thermoplastics at temperatures above 200°F.

“When comparing the actual requirements and expectations contained in NAPA’s guidance document with the 2018 version of the STI/SPFA SP001 Standard, the inspection standards involving environmental protection controls weren’t changed much,” Bigham says. “What was changed significantly was the scheduling of the inspections after initial installation, and the procedures for ensuring the inspections were properly done, including the use of STI/SPFA-certified inspectors at applicable intervals. These varied greatly between the NAPA Guidance and the new STI/SPFA SP001.

“With the 2018 changes in place, SP001 is now able to be used for the inspection of not just ASTs storing asphalt cement, but could now also be used to inspect ASTs storing other liquids with similar characteristics at asphalt pavement production facilities, such as additives and heated tack. This is an improvement over the NAPA Guidance, which was limited to ASTs storing asphalt cement only.”

The revisions to SP001 will require ASTs storing asphalt cement to have inspections conducted according to the procedures contained in the new Appendix D – Inspection of Thermoplastic ASTs. Many of these inspections can be performed by knowledgeable facility personnel. Some of the inspections will need to be performed by an SP001 Certified Inspector.

“Generally, the SP001 inspection protocol recommends monthly inspections,” Bigham says. “These can be done in almost all cases by facility personnel (caution - some jurisdictions may requirement more frequent inspections). Shop built tanks that have spill control and Continuous Release Detection Monitoring (CRDM) can be inspected by plant personnel for the entire life of the tank. ASTs lacking spill control or CRDM (such as having the tank elevated) will need at certain intervals to be inspected by an SP001 Certified Inspector. The SP001 Certified Inspector can either be a company employee or a third-party inspector. The training course at the World of Asphalt will go over the specifics of the inspection schedule.

However, Bigham notes that an inspection by a governmental agency is a different matter.

Most regulatory agencies, whether federal, state or local, are not required to inform a facility that they are preparing to inspect that facility. However, as a matter of practicality many agencies do let facilities know of an inspection beforehand. This is done so that the inspection can be done more efficiently and more comprehensively.

“The most important thing facility management can do to have a fair inspection done by a regulator is to have the key people at the facility during the inspection,” Bigham says. “This can’t be stressed enough. If the facility manager is also operating the control room and manning the scales at the time of an inspection, there is no way that individual can properly guide the governmental inspector around the facility or answer the myriad number of questions that will be asked.”

It is critical that facility management have knowledgeable staff assist the government inspector. Sometimes well-meaning but untrained facility personnel can give answers not reflective of company policy. Be certain to have enough trained, trusted personnel on-hand to so that all questions that are asked are given the correct response. If possible, you may want to arrange to have the SP001 inspector you used on-hand to answer questions about how the SP001 inspection was conducted.

“Virtually every facility affected by the new Standard will also have above ground storage tanks and containers containing other regulated liquids, such as diesel fuel, gasoline, fuel oil, used oil, lube oil and transmission fluid,” Bigham says. “Many of the tanks will need to be inspected according to the SP001 Standard, depending on their size, construction and age. It may be cost-effective to have all tanks needing inspection be evaluated at one time.”

For more information on this topic, be sure to attend Bigham’s World of Asphalt Education session, Tue. March 6 2:00 PM - 3:30 PM. Register at www.worldofasphalt.com

Developing a SPCC

All facilities that have a storage capacity of 1,320 gallons or more of a regulated liquid need to have a federally-mandated Spill Prevention, Control and Countermeasure (SPCC) Plan. This includes virtually all asphalt pavement production facilities, terminals and most stand-alone vehicle and maintenance shops. A regulated liquid includes all petroleum-derived products, including, but not limited to asphalt cement, diesel fuel, gasoline, used oil and lube oils. The total capacity is calculated by adding up the individual capacity of all tanks and containers (including totes) that are 55-gallons in size or greater.

Any facility with 10,000 gallons or greater in total capacity must have the SPCC Plan approved and signed by a registered P.E. All SPCC Plans, whether they require a P.E.’s sign-off or not, must include a discussion (including the inspection schedule) of the relevant “industry standard” used to satisfy the federal requirement for inspections. That is why the modification of STI/SPFA’s SP001 is of importance to anyone handling asphalt cement or other “thermoplastic” liquids.

According to Bigham, general facility information usually comes first on your SPCC. This includes company ownership information, contact information, the layout of the site, including all tanks, drains, water conveyances, roads, utilities, etc. Next should be description of the location of the facility, with maps, discussion of routes to the facility and operating hours. There needs to be information about site security.

A detailed discussion is needed of how all regulated liquids are stored and handled. This includes tank loading, off-loading and dispensing. Included with that are details about near-by waterways (including drainage structures).

A complete SPCC Plan will have information about the potential spillage for each tank (or groups of tanks, if similar), the possible cause of the release, the anticipated direction of the flow, and likely volume of the release. The Plan will discuss any previous spills that occur over the preceding twelve months, all spill prevention measures, especially containment and diversion structures.

Next, the discussion about the tanks and facility inspections should be placed here, focusing on just not the tanks, but on the entire facility, including the types of personnel on-staff, their job functions, training, and procedures in place to respond to a release.

The Plan needs to discuss what happens immediately after a release is discovered, the procedures in place to promptly respond, the types (and locations) of spill response materials kept on-site, all spill mitigation measures, and lastly, a plan for disposing of all spill response-related debris and recovered product.

Usually included in a SPCC Plan are diagrams of the facility, copies of all inspection forms, including drainage logs, training logs, procedures for notification of a release, and facility contact information. Also, a complete Plan will have charts or tables showing all tank and drum status, containment type, formal inspection dates, containment capacity calculations and any other information necessary to give a comprehensive overview as to how oil and other regulated liquids are handled at the facility, including compliance measures taken to meet other environmental regulatory requirements.

In addition to the requirements under federal 40 CFR 112, many states have their own regulations that may add new requirements to the SPCC Plan. Some examples of states-only requirements from state environmental agencies include tank and facility permitting, state-certified inspectors, weekly inspection frequencies, inclusion of storm water plans with SPCC Plans and submittal of federal SPCC Plans for state review. Many states have the authority to enforce the required inspections of ASTs using SP001 as the Standard.

There are other requirements imposed by agencies other than state environmental agencies that need to be included either in the SPCC Plan or are part of an STI/SPFA SP001 inspection. Fire codes, enforced by state or local fire officials are often used to implement many of these additional requirements. NFPA 30 and NFPA 30A, both of which set standards for storage tank operation and management, have been adopted in at least 30 states. For example, a Class III B liquid such as asphalt cement faces certain restrictions as to how containment with Class I and II liquids may occur. Many of the remaining States adopted the International Fire Code which incorporates, either verbatim or by reference much of the same language as what appears in NFPA 30 and 30A.

Documentation Needed

For an SP001 inspection by either in-house or third-party inspectors, the following documents will be needed, if available:

- A copy of the SPCC Plan

- Site Plan

- Documents relating to the design, construction and installation of the ASTs to be inspected

When an inspection by a government agency is to occur, in addition to the documents listed above, the facility needs to have on-hand:

- A SIGNED copy of the SPCC Plan

- All monthly and annual inspection reports

- The SP001 inspection reports

- Containment drainage logs (if applicable)

- Training logs

- Copies of any state or local permits in place for the facility

Tank Types

For inspection purpose ASTs are divided into two types. The two types differ in their construction. One type of AST is built on-site and is referred to as a “field-erected” AST. The other type of AST is built in a shop and transported to the location where it is to be used and is known as a “shop-built” AST.

Field-erected ASTs that are for the storage of asphalt cement are generally larger and are found most often at terminals. These tanks can vary in size, with some up to several million gallons in capacity.

Shop-built ASTs usually are smaller, maxing out at 75,000 gallons in capacity. Shop-built ASTs are generally found at facilities that produce asphalt paving mixtures. While many sizes are available, most tanks that store asphalt cement range from 10,000 to 35,000 gallons in size.

Field-erected tanks storing asphalt cement can be inspected using the American Petroleum Institute’s (API) 653 Standard for Tank Inspection, Repair, Alteration, and Reconstruction. API 653 can be modified to account for the elevated temperature encountered when inspecting tanks storing asphalt cement.

Shop-built tanks, storing a wide array of regulated liquids such as gasoline and fuel oil generally are inspected using STI/SPFA’s SP001 Standard. This inspection standard is used extensively throughout the U.S. for shop-built ASTs, portable containers, as well as smaller field-erected tanks up to a maximum shell height of 50 feet and a maximum diameter of 30 feet. However, until recently, it hasn’t been able to be used for shop-built ASTs storing heated asphalt cement as the standard wasn’t designed to include ASTs holding liquids over 200°F.