Tank Inspection 101
One of the basic concepts of environmental compliance is the periodic tank inspection.
Regardless of the type of material being stored, under federal or state environmental requirements, some type of periodic inspection is always required. These periodic inspections are like a tool with many functions, from simple monitoring to status checks to extensive compliance assurance evaluations.
A frequently overlooked and under-performed area of periodic inspection is related to storage tanks and similar types of containers at industrial facilities.
Tank inspection requirements typically cover multiple environmental areas, with the Clean Air Act (CAA), Resource Conservation and Recovery Act (RCRA), and Clean Water Act (CWA) through the Spill Prevention, Control and Countermeasures (SPCC) provisions contributing the bulk of the requirements.
Although the specific requirements will vary based on the storage tank specifications, site-specific regulatory requirements, and other factors, there are several common requirements that pertain to most tanks. When preparing to perform a tank inspection at an industrial site, outside items other than just the physical storage tank need to be taken into consideration.
IS COMPLIANCE IMPORTANT TO YOUR BUSINESS?
Establishing a tank inspection program that includes a consolidation of all necessary applicable requirements detailed on the periodic inspection forms is the key to this concept of environmental compliance.
Common Tank Inspection Logs include the following record-keeping ~
- Secondary Containment Area Compliance Checklist:
- Free of debris and/or water?
- Drain line valves closed/sump pumps off unless being emptied of clean water?
- Structurally acceptable condition:
- Would the secondary containment retain its contents if a catastrophic failure occurred, such as a tank rupture?
- Are the concrete coating and joint compounds (if required) of good integrity?
Storage Tank Compliance Checklist:
- When was the last tank integrity inspection conducted?
- Does the general condition of the tank appear OK?
- Are there any signs of leakage, corrosion, deterioration or other damage?
- Any visible signs of leakage or spillage from the associated ancillary equipment...
- other Fittings?
- Is the general condition of the tank system ancillary equipment OK?
- Is the level monitor (if required/equipped) functional/working?
- Is the tank equipped with a mixer?
- Lock-out / Tag-out used as part of the tank cleaning process?
- Are all tanks/containers legibly labeled with contents?
- Are tanks being inspected per the tank design standards schedule?
- Have all applicable Plant Personnel been notified of storage tanks that are temporarily out of service?
- Has out of service storage tank been locked-out to prevent the adding of material?
- Records On-hand and Readily Available Compliance Checklist:
- Periodic dated inspection records containing documentation of deficiency and corrective actions?
- Record retention meets regulatory requirements or the life of the tank?
- Documentation of secondary containment drainage of stormwater and the standard operating procedures of visually/testing water clarity prior to discharge?
- Employee training records for the management of tank/container spills and secondary containment discharges?
- Previous inspections, tank integrity testing and tank repairs?
- Qualifications/Accreditation of individual or entity conducting the inspection?
- API or applicable standards specified for inspection?
- Recorded interior tank conditions if an entry is required?
Navigating through all the potential specific regulatory requirements for tank inspections at an industrial facility and consolidating them into a usable, real-world format can be a time consuming and cumbersome task. If not sufficiently versed in one or more environmental areas, applicable inspection requirements can be easily overlooked and thereby omitted from the compliance record.
Tradebe can assist facilities with their tank inspection program, as well as industrial cleanings, maintenance, and plant turnaround management.
Read more about these and other industrial services performed by Tradebe
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