April 2, 2024 • 12 mins
In this episode, we gear up for the warmer months, focusing on SPCCs and STIs. We'll break down the essentials of Spill Prevention and Countermeasure (SPCC)plans and how they integrate with Steel Tank Institute (STI) inspection standards to ensure robust fuel storage practices. Our experts will share practical tips and insights on maintaining compliance and operational efficiency during the busy summer. Whether managing bulk fuel facilities or interested in industry best practices, this episode provides valuable knowledge to keep you prepared and proactive. Tune in to stay ahead of the curve and ensure your operations are summer-ready.
Episode Transcription
ADDITIONAL RESOURCES:
40 CFR 112
STI Standard
STI Certified Inspectors
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 occur from using 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, which would be me or Integrity Environmental. Thank you very much for listening. If you need professional regulatory advice, we would be happy to provide it as part of our consulting services.
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Amanda (00:01):
Welcome back Shannon.
How are you doing today?
Shannon (00:03):
I'm doing really well.
Spring has sprung and I'mreally excited for the upcoming
summer season.
Things are really moving andshaking and I always like this
time, right before we go outinto the field.
It's just full of anticipationand freshness.
Amanda (00:19):
Oh yeah, and summertime, that's when we pick up our tank
inspections.
Shannon (00:23):
And summertime.
That's when we pick up our tankinspections.
It's true, we do most of ourtank inspections when the air
temperature is warmer than 34degrees.
Amanda (00:32):
It's comforting.
So I've noticed that SPCC plansand STI inspections often occur
together.
Why?
Shannon (00:41):
is that?
You know we get that questionfrom our clients a lot and the
answer is a change to the SPCCrequirement in 2002, but also an
enforcement in 2011.
There's a very specific part ofthe SPCC regulation,
specifically 40 CFR 112.8.6.
(01:04):
Let me quote directly from itTest or inspect each
above-ground container forintegrity on a regular schedule
and whenever you make thematerial repairs, you must
determine, in accordance withindustry standards, the
appropriate qualifications forpersonnel performing tests and
inspections, the frequency andtype of testing and inspections,
(01:24):
tests and inspections, thefrequency and type of testing
and inspections.
So this change to the SPCC code10 years ago meant that all of
the principal engineers thatwere reviewing SPCCs and
approving them which is arequirement also of the SPCC
plan they had to show that therewas some sort of testing
program of all the bulk fuelstorage containers in accordance
with industry standards.
(01:45):
And for most SPCC facilitiesthe appropriate standard is STI
SP001.
Amanda (01:52):
What does the SP001 mean ?
Shannon (02:00):
You know, that's a really good question and I just
learned that during a training Itook.
So the STI stands for SteelTank Institute and then the SP
stands for Standard Practice,which means it's an industry
standard practice.
There's also language that saysRP and that means recommended
practice, and so recommendedpractice is sort of like best
management practices, good ideas.
Sp means standard practice andthat means it's generally
(02:22):
accepted by the engineeringcommunity as the standard
practice for whatever thestandard applies to.
And then the 001 part meansthat it was created in 2000.
And it's the first edition 1001.
Amanda (02:37):
That's pretty clever.
Shannon (02:39):
Yes, where would the standard apply?
Well, that standard coversstationary tanks and it also
covers portable containers andit covers mostly horizontal
tanks but also some verticals,because the UL 142 and the UL
2085 construction standards theyhave a lot of flexibility, so
(03:01):
you got a lot of different kindsof tanks out there.
Flexibility, so you got a lotof different kinds of tanks out
there, and so the STI broadlyapplies to pretty much every
kind of tank sort of under the75,000 gallons and even some up
to maybe 200,000 gallons, butthose are pretty rare.
Generally, we see the STI SP001standard applied to your very
stereotypical horizontal tankthat could be anywhere from 275
(03:25):
gallons all the way up to 50,000or 75,000.
Amanda (03:29):
Wow.
What do SPCC managers need toknow about STI?
Shannon (03:34):
When an engineer selects the STI standard for
your tank inspection program,there are two components to it.
One is an in-house componentwhere somebody knowledgeable
about the tank and its operationfrom the facility performs a
monthly and an annual inspection.
And when we audit facilities wefrequently find that that's not
(03:56):
being performed on paper.
The terminal manager, of course, is looking at his tank and he
notices if something's not rightor, you know, is out of whack.
But documenting it on a pieceof paper monthly and annually,
specifically in the STI format,doesn't happen as frequently.
So if I was managing an SPCCplan I'd want to make sure that
I understood that there is amonthly and an annual component
(04:18):
to that that you're supposed tobe doing internally.
And then there's an externalcomponent where an STI certified
inspector has to inspect somekinds of horizontal tanks but
not all and so smaller tanksthat are fully within secondary
containment and have certainspill control and overfill
prevention devices.
You will only ever need to doan internal inspection to make
(04:41):
sure that things are correct andmeeting the STI standard.
But as tanks get bigger, therisk for an overfill or a spill
gets bigger, right, becausethere's more fuel to spill, and
so the STI standard generallytanks over 5,000 gallons in size
or tanks that are not within asecondary containment system.
They require inspection by acertified inspector from outside
(05:03):
your company that has specialcertifications and they come and
they actually inspect the tank,they take some UTT data and
they also create a formalexternal or internal inspection
report for your tank, dependingon what kind of tank.
That report will typicallyinclude photos and they'll map
out your tank and theappurtenances and it's a really
(05:23):
good document for your tank,just to know more about your
tank.
But it's also something you haveto keep for the life of your
tank and the SPCC refers to thatand requires those external
inspections for those specifictanks.
So somewhere in your SPCC planyou have a table and in that
table it says when your tankinspections are due and who is
to perform them, and sometimespeople who have older SPCCs that
(05:46):
they haven't updated recently.
You're supposed to require toupdate it every five years but
sometimes that falls by thewayside and the older SPCCs that
are older than 10 yearssometimes don't have the
inspection schedule because itwasn't a requirement like it is
now in the modern SPCC world.
So if you're an SPCC manager,those are the two things I think
(06:08):
you really need to focus on isthat those tanks are supposed to
be having monthly and annualperformed in-house, and that
some of your larger tanks willhave an external component and
the reason when our firm getscalled for an SPCC.
Oftentimes we're the first oneto have rewritten the SPCC or
we're creating a new SPCC andthe tanks have been on site for
a long time but have never beeninspected, or they don't have
(06:29):
any inspection records that havebeen kept, and so for our PE to
sign off on, we have to have anSTI SP001 inspection record,
especially for the bigger tanks.
Amanda (06:40):
So that's why they go together.
All right, and that sounds likea pretty thorough inspection.
How would someone go aboutfinding a certified STI
inspector?
Shannon (06:49):
Well, you could call us and we have several on staff.
You can actually write to STIand get a list of the certified
inspectors that are current andyou can sort that Excel sheet by
state or location or region.
You also want to make sure whenyou are hiring an STI inspector
that their STI inspectioncredentials will be current when
they're performing theinspection.
(07:09):
We've had a couple that clientshave provided to us to review
where the STI inspector hiscertificate expired before they
went out to the site, like itwas current when they made the
plans but then of course itexceeded that.
So you're going to want to makesure that they have that
current certification.
And, yeah, you can go directlyto the STI SP001 website, which
(07:31):
we can absolutely leave in theshow notes, and there is a
button to request a list of STIinspectors and you can sort of
cross-check or go shopping usingthat list.
Look for me, I'm on it.
Amanda (07:44):
That's convenient.
What should we be looking at inthe STI report when it comes
back specific to the SPCCrequirements?
Shannon (07:54):
For a formal external or internal inspection by a
certified inspector.
You're going to want to lookfor a couple of things.
The SPCC program wants to makesure that you have adequate
secondary containment measuresand the STI allows for different
kinds of spill preventionmethods and they don't always
(08:17):
match up with the SPCC.
For example, a double-walledtank.
The double wall acts as asecondary containment Under an
STI inspection.
If there is a double walledtank and there's overfill
prevention provided by a personattending all filling events,
that's considered a category onetank and it's good to go.
(08:38):
You don't have to have itinside secondary containment.
But the SPCC regulations haveadditional stuff on top.
They say you have to havespecific overfill prevention
devices installed on the tankfor that tank to not be within
secondary containment.
So, that's one thing you want tolook at is to make sure that
your SPCC requirements matchwith what the STI report is
(08:59):
reporting back and not assumethat because the STI says you're
good to go, that you're good togo with the SPCC, the SPCC
trumps the STI.
The other thing you're going towant to look for is to make sure
your report is thorough and haslots of photographs and if they
say something like if nozzle Cappears to have damage, that it
actually identifies what theinspector thought nozzle C was.
(09:19):
It's got sort of a diagram or afigure that shows where all the
things this person is talkingabout the inspector is talking
about, so that you can go andlook at your own tank and
identify those things.
The other thing you want tolook at is the inspection
intervals, because for STIs mostof these inspection intervals
are a formal external every 20years if everything's good on
(09:40):
your tank.
If your tank inspectioninterval is lower than that 10
years, 5 years that means thatyou're missing some critical
components like releasedetection or spill control, and
you can extend the length oftime between inspections if you
add things like an impermeablecontainment area or a dike or
add an overfill prevention alarmto your tank.
(10:02):
So, sometimes if you get an STIreport back and they say, oh,
we've got to come back in fiveyears, if I was in your position
of reviewing these reports, I'dbe like, well, what could I do
to make that 10 or 20?
What could I do to this tankthat would then make me a
different category of tank andallow me to have a longer formal
inspection interval.
Amanda (10:20):
All right, and is there any guidance from the EPA
surrounding portable containers?
Shannon (10:26):
Yes, the EPA issued a bulk storage container integrity
testing guidance and we willlink that in our show notes.
The EPA asserts, rightly so,that tanks are not the only
thing that can leak Containerscan too.
And so if your containers are abigger size, over that
55-gallon threshold, they wantto know that you're doing
(10:48):
integrity testing and inspectingand monitoring and preventing
leaks and spills so that you'renot impacting the environment.
And this guidance is a littlethick.
It does talk about developing aprogram for inspecting or
testing your containers, andthat is something that everyone
needs to have.
It doesn't have to be difficult.
It can be simple, but, as youknow if you've listened to this
(11:09):
podcast before, simple is notalways easy, and so it does help
, especially if you've got afacility with multiple tanks,
containers and all sorts ofthings going on.
Firms like ours can be a goodhelp of sort of helping you set
up that inspection program andmaking sure you know how to run
it and provide training forpeople that are filling out all
these monthly and quarterliesand annuals.
(11:30):
But if you're a DIYer, you canget most of that information
from the EPA as well.
And then the STI website alsohas some pretty good guidance on
portable containers and theyhave a free inspection checklist
for portable containers.
Amanda (11:45):
Perfect.
Well, we'll include that in theshow notes so our listeners can
jump in.
Shannon (11:50):
Yeah, if people have questions, they're more than
welcome to reach out to me andrun them by me.
Portable containers make thingsa little complicated and so,
yeah, if you have a question,feel free to drop me a line in
an email and I'd be happy tohelp you out.
Since we're done with today'srun through of SPCC and STI BFFs
forever, I was thinking wecould put a link to the STI
(12:11):
website and on there you canrequest that list of inspectors.
You can also download for freethe monthly and annual
inspection checklist examples,and we can also include that PDF
straight as a link in our shownotes.
And then I will definitely puta link to 40 CFR 112.
So you can go read thatregulation yourself, if my
(12:33):
version of it was not satisfying.
Amanda (12:37):
I doubt it.
Well, thank you so much,shannon, for joining us today
and explaining how SPCC plansand STI inspections work
together, and I look forward toour next chat.
Yeah, thanks, amanda.
Shannon (12:50):
Thanks for hosting Bye.
Amanda (12:51):
Bye.
Welcome back Shannon.
How are you doing today?
Shannon (00:03):
I'm doing really well.
Spring has sprung and I'mreally excited for the upcoming
summer season.
Things are really moving andshaking and I always like this
time, right before we go outinto the field.
It's just full of anticipationand freshness.
Amanda (00:19):
Oh yeah, and summertime, that's when we pick up our tank
inspections.
Shannon (00:23):
And summertime.
That's when we pick up our tankinspections.
It's true, we do most of ourtank inspections when the air
temperature is warmer than 34degrees.
Amanda (00:32):
It's comforting.
So I've noticed that SPCC plansand STI inspections often occur
together.
Why?
Shannon (00:41):
is that?
You know we get that questionfrom our clients a lot and the
answer is a change to the SPCCrequirement in 2002, but also an
enforcement in 2011.
There's a very specific part ofthe SPCC regulation,
specifically 40 CFR 112.8.6.
(01:04):
Let me quote directly from itTest or inspect each
above-ground container forintegrity on a regular schedule
and whenever you make thematerial repairs, you must
determine, in accordance withindustry standards, the
appropriate qualifications forpersonnel performing tests and
inspections, the frequency andtype of testing and inspections,
(01:24):
tests and inspections, thefrequency and type of testing
and inspections.
So this change to the SPCC code10 years ago meant that all of
the principal engineers thatwere reviewing SPCCs and
approving them which is arequirement also of the SPCC
plan they had to show that therewas some sort of testing
program of all the bulk fuelstorage containers in accordance
with industry standards.
(01:45):
And for most SPCC facilitiesthe appropriate standard is STI
SP001.
Amanda (01:52):
What does the SP001 mean ?
Shannon (02:00):
You know, that's a really good question and I just
learned that during a training Itook.
So the STI stands for SteelTank Institute and then the SP
stands for Standard Practice,which means it's an industry
standard practice.
There's also language that saysRP and that means recommended
practice, and so recommendedpractice is sort of like best
management practices, good ideas.
Sp means standard practice andthat means it's generally
(02:22):
accepted by the engineeringcommunity as the standard
practice for whatever thestandard applies to.
And then the 001 part meansthat it was created in 2000.
And it's the first edition 1001.
Amanda (02:37):
That's pretty clever.
Shannon (02:39):
Yes, where would the standard apply?
Well, that standard coversstationary tanks and it also
covers portable containers andit covers mostly horizontal
tanks but also some verticals,because the UL 142 and the UL
2085 construction standards theyhave a lot of flexibility, so
(03:01):
you got a lot of different kindsof tanks out there.
Flexibility, so you got a lotof different kinds of tanks out
there, and so the STI broadlyapplies to pretty much every
kind of tank sort of under the75,000 gallons and even some up
to maybe 200,000 gallons, butthose are pretty rare.
Generally, we see the STI SP001standard applied to your very
stereotypical horizontal tankthat could be anywhere from 275
(03:25):
gallons all the way up to 50,000or 75,000.
Amanda (03:29):
Wow.
What do SPCC managers need toknow about STI?
Shannon (03:34):
When an engineer selects the STI standard for
your tank inspection program,there are two components to it.
One is an in-house componentwhere somebody knowledgeable
about the tank and its operationfrom the facility performs a
monthly and an annual inspection.
And when we audit facilities wefrequently find that that's not
(03:56):
being performed on paper.
The terminal manager, of course, is looking at his tank and he
notices if something's not rightor, you know, is out of whack.
But documenting it on a pieceof paper monthly and annually,
specifically in the STI format,doesn't happen as frequently.
So if I was managing an SPCCplan I'd want to make sure that
I understood that there is amonthly and an annual component
(04:18):
to that that you're supposed tobe doing internally.
And then there's an externalcomponent where an STI certified
inspector has to inspect somekinds of horizontal tanks but
not all and so smaller tanksthat are fully within secondary
containment and have certainspill control and overfill
prevention devices.
You will only ever need to doan internal inspection to make
(04:41):
sure that things are correct andmeeting the STI standard.
But as tanks get bigger, therisk for an overfill or a spill
gets bigger, right, becausethere's more fuel to spill, and
so the STI standard generallytanks over 5,000 gallons in size
or tanks that are not within asecondary containment system.
They require inspection by acertified inspector from outside
(05:03):
your company that has specialcertifications and they come and
they actually inspect the tank,they take some UTT data and
they also create a formalexternal or internal inspection
report for your tank, dependingon what kind of tank.
That report will typicallyinclude photos and they'll map
out your tank and theappurtenances and it's a really
(05:23):
good document for your tank,just to know more about your
tank.
But it's also something you haveto keep for the life of your
tank and the SPCC refers to thatand requires those external
inspections for those specifictanks.
So somewhere in your SPCC planyou have a table and in that
table it says when your tankinspections are due and who is
to perform them, and sometimespeople who have older SPCCs that
(05:46):
they haven't updated recently.
You're supposed to require toupdate it every five years but
sometimes that falls by thewayside and the older SPCCs that
are older than 10 yearssometimes don't have the
inspection schedule because itwasn't a requirement like it is
now in the modern SPCC world.
So if you're an SPCC manager,those are the two things I think
(06:08):
you really need to focus on isthat those tanks are supposed to
be having monthly and annualperformed in-house, and that
some of your larger tanks willhave an external component and
the reason when our firm getscalled for an SPCC.
Oftentimes we're the first oneto have rewritten the SPCC or
we're creating a new SPCC andthe tanks have been on site for
a long time but have never beeninspected, or they don't have
(06:29):
any inspection records that havebeen kept, and so for our PE to
sign off on, we have to have anSTI SP001 inspection record,
especially for the bigger tanks.
Amanda (06:40):
So that's why they go together.
All right, and that sounds likea pretty thorough inspection.
How would someone go aboutfinding a certified STI
inspector?
Shannon (06:49):
Well, you could call us and we have several on staff.
You can actually write to STIand get a list of the certified
inspectors that are current andyou can sort that Excel sheet by
state or location or region.
You also want to make sure whenyou are hiring an STI inspector
that their STI inspectioncredentials will be current when
they're performing theinspection.
(07:09):
We've had a couple that clientshave provided to us to review
where the STI inspector hiscertificate expired before they
went out to the site, like itwas current when they made the
plans but then of course itexceeded that.
So you're going to want to makesure that they have that
current certification.
And, yeah, you can go directlyto the STI SP001 website, which
(07:31):
we can absolutely leave in theshow notes, and there is a
button to request a list of STIinspectors and you can sort of
cross-check or go shopping usingthat list.
Look for me, I'm on it.
Amanda (07:44):
That's convenient.
What should we be looking at inthe STI report when it comes
back specific to the SPCCrequirements?
Shannon (07:54):
For a formal external or internal inspection by a
certified inspector.
You're going to want to lookfor a couple of things.
The SPCC program wants to makesure that you have adequate
secondary containment measuresand the STI allows for different
kinds of spill preventionmethods and they don't always
(08:17):
match up with the SPCC.
For example, a double-walledtank.
The double wall acts as asecondary containment Under an
STI inspection.
If there is a double walledtank and there's overfill
prevention provided by a personattending all filling events,
that's considered a category onetank and it's good to go.
(08:38):
You don't have to have itinside secondary containment.
But the SPCC regulations haveadditional stuff on top.
They say you have to havespecific overfill prevention
devices installed on the tankfor that tank to not be within
secondary containment.
So, that's one thing you want tolook at is to make sure that
your SPCC requirements matchwith what the STI report is
(08:59):
reporting back and not assumethat because the STI says you're
good to go, that you're good togo with the SPCC, the SPCC
trumps the STI.
The other thing you're going towant to look for is to make sure
your report is thorough and haslots of photographs and if they
say something like if nozzle Cappears to have damage, that it
actually identifies what theinspector thought nozzle C was.
(09:19):
It's got sort of a diagram or afigure that shows where all the
things this person is talkingabout the inspector is talking
about, so that you can go andlook at your own tank and
identify those things.
The other thing you want tolook at is the inspection
intervals, because for STIs mostof these inspection intervals
are a formal external every 20years if everything's good on
(09:40):
your tank.
If your tank inspectioninterval is lower than that 10
years, 5 years that means thatyou're missing some critical
components like releasedetection or spill control, and
you can extend the length oftime between inspections if you
add things like an impermeablecontainment area or a dike or
add an overfill prevention alarmto your tank.
(10:02):
So, sometimes if you get an STIreport back and they say, oh,
we've got to come back in fiveyears, if I was in your position
of reviewing these reports, I'dbe like, well, what could I do
to make that 10 or 20?
What could I do to this tankthat would then make me a
different category of tank andallow me to have a longer formal
inspection interval.
Amanda (10:20):
All right, and is there any guidance from the EPA
surrounding portable containers?
Shannon (10:26):
Yes, the EPA issued a bulk storage container integrity
testing guidance and we willlink that in our show notes.
The EPA asserts, rightly so,that tanks are not the only
thing that can leak Containerscan too.
And so if your containers are abigger size, over that
55-gallon threshold, they wantto know that you're doing
(10:48):
integrity testing and inspectingand monitoring and preventing
leaks and spills so that you'renot impacting the environment.
And this guidance is a littlethick.
It does talk about developing aprogram for inspecting or
testing your containers, andthat is something that everyone
needs to have.
It doesn't have to be difficult.
It can be simple, but, as youknow if you've listened to this
(11:09):
podcast before, simple is notalways easy, and so it does help
, especially if you've got afacility with multiple tanks,
containers and all sorts ofthings going on.
Firms like ours can be a goodhelp of sort of helping you set
up that inspection program andmaking sure you know how to run
it and provide training forpeople that are filling out all
these monthly and quarterliesand annuals.
(11:30):
But if you're a DIYer, you canget most of that information
from the EPA as well.
And then the STI website alsohas some pretty good guidance on
portable containers and theyhave a free inspection checklist
for portable containers.
Amanda (11:45):
Perfect.
Well, we'll include that in theshow notes so our listeners can
jump in.
Shannon (11:50):
Yeah, if people have questions, they're more than
welcome to reach out to me andrun them by me.
Portable containers make thingsa little complicated and so,
yeah, if you have a question,feel free to drop me a line in
an email and I'd be happy tohelp you out.
Since we're done with today'srun through of SPCC and STI BFFs
forever, I was thinking wecould put a link to the STI
(12:11):
website and on there you canrequest that list of inspectors.
You can also download for freethe monthly and annual
inspection checklist examples,and we can also include that PDF
straight as a link in our shownotes.
And then I will definitely puta link to 40 CFR 112.
So you can go read thatregulation yourself, if my
(12:33):
version of it was not satisfying.
Amanda (12:37):
I doubt it.
Well, thank you so much,shannon, for joining us today
and explaining how SPCC plansand STI inspections work
together, and I look forward toour next chat.
Yeah, thanks, amanda.
Shannon (12:50):
Thanks for hosting Bye.
Amanda (12:51):
Bye.
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