STI SP001 with Experts

Episode Transcript
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Haley Hall (00:10):
Welcome to Tank Talk with Integrity Environmental.
Join us as we sit down withfounder, principal consultant
and bulk fuel storage expert,Shannon Oelkers, to explore
regulations, safety andessential tips for navigating
the bulk fuel storage industry.
Join us as we explore theunique joys of work and life in
Alaska with industry experts,including our team, vendors we

(00:30):
work with, and the companies wesupport.

Shannon Oelkers (00:36):
Hello, welcome to Tank Talk.
This is Shannon Oelkers here,and I am very excited today
because I have two very specialguests.
I have Joe Mentzer with the STISPFA organization, and then I
have Craig Fletcher fromFletcher Consultants Inc.
Both are recognized experts inabove ground storage tanks.
I have taken classes from bothof these gentlemen that I have

(00:58):
enjoyed greatly over the years.
I've taken two from Joe, andCraig Fletcher was the one that
got me my STI certification forcertified inspector.
I'm so glad to have both of youhere today to talk about the
STI SP-001 standard.
So welcome.
I appreciate you being here somuch.
Glad to be here.
Yeah, Before we get into the STI, which I am dying to do, STI

(01:22):
SP-001.
I was hoping you guys couldintroduce yourselves briefly and
maybe give me a brief overviewof your career, how you fell in
or backed into tanks and thenwe'll start talking about the
STI SP-001.

Joe Mentzer (01:35):
My name is Joe Mentzer.
I am the standards engineer forSTI SPFA, which is the Steel
Tank Institute Steel PlateFabricators Association.
I have been in this role since2019.
Prior to that, I was aconsultant in Wisconsin and I
did stuff with people who storedjust about anything.
When I started working in theenvironmental world, I would

(01:58):
address spills, mostly fromunderground storage tanks, and I
cleaned up a lot of tanks and Ifinally had one of my first
customers in fact may have beenone of my first customers says
great, you can clean it up, canyou make it not leak in the
first place?
And that was sort of mybusiness plan.
The other part was, as theywere cleaning up or replacing
gas stations, they would runinto problems and it would

(02:20):
interfere with the installation.
So, since I was doing thecleanup, I had to learn the
installation process so I couldfacilitate cleaning up the site
and installing it.
Well, then it moved to aboveground tanks and then it moved
to.
I worked with a lot of weirdchemicals the printing industry,
the food industry, thepharmaceutical industry so then
I got into the hazardous stuffand I was a consultant for many,

(02:41):
many years and I was a SPO1inspector since 2001.
My state adopted that early.
Wisconsin is where I did mostof my work Adopted that program
early, I got involved with thatand I met the folks at STI and
then, when my predecessorretired, the job opened up and
consulting had been a good run,but it was time to try something

(03:03):
different.
So I ended up moving here.
But I've worked in thepetroleum industry, certainly,
but also several otherindustries that store really
interesting stuff.

Spoken like a true engineer.
Chemicals, that would make myhair go gray.
You're like that's interesting.

Like this chemical.
It looks like water, it has noodor, but if you get it on your
skin it might kill you.
Oh, okay.

Great.
That's how I feel aboutmethanol.
It can be on fire and you wouldnever know.

Craig Fletcher (03:30):
That scares the crap out of me.

Yeah, that's another one, all right.

So Craig, you want to introduce yourself.

Sure, I'm Craig Fletcher.
I'm the principal of FletcherConsultants.
We're a small California-basedenvironmental consulting firm
that does a wide variety ofenvironmental consulting
services for a host of clients.
In terms of the company itself,we've been around about 23
years.
We provide everything frompreparing SPCC plans, spill
prevention, control andcountermeasure plans to

(04:00):
hazardous waste tankcertifications, as well as doing
many other types ofenvironmental compliance stuff,
including hazardous wastefacility permitting.
We've also done a whole varietyof soil investigations and
other types of work.
Getting back into the, I've beenan STI inspector since 2009.
And early on when the SPCC planregulations were being changed,

(04:23):
I recognized early on the needfor having because of the
requirement to have thefollowing an industry standard,
the need for having the trainingin the STI program and becoming
certified.
So that's kind of it in anutshell.
Prior to starting this firm, Iworked for Pacific Gas and
Electric Company, pg&e, theutility out here for 10 years

(04:44):
and that's probably where Ifirst got more into tanks, where
I worked at a power plant wherewe had about I think it was 18
or 19 million gallons worth ofpetroleum storage there.
So it was a very complexfacility that had a lot of
different aspects to it.
Prior to that I was in gradschool.
Prior to that, I worked inenvironmental consulting as a
geologist.
Before then I was actually Iworked in exploration geology

(05:07):
for Chevron, USA.
So that's we're getting backinto the just the wooly mammoth
perished, but in terms of mycareer.
But that kind of gives you thenutshell.

Okay, and then, Craig, you have a geology
background, is that correct?

That's true.

And then Joe, you're okay, yeah, I have a
geology background.
Is that correct?
That's true.
And then, joe, you're.

Okay, yeah, I'm a professional geologist.
And then, joe, you'reengineering.
Yeah, I am an engineer.
I'm actually a mining engineer.
I got my degree in Madison,Wisconsin, in mining.
I like geology.

Okay, I do too.
Surprisingly, I have a biologybackground.
I don't know how I ended uphere, but I love it.
So thank you both for agreeingto be here today to talk about
the STI SP001.
Our longtime listeners, theyknow how much I love to talk
about STI and there's a goodreason for that.

(05:55):
I think 99% of the facilities wework with have shop fabricated
or shop built tanks as part oftheir inventory and there's a
lot of regulatory ties, as Craigmentioned, to the STI SP00
standard in particular, bothwith the SPCC and then for our
Alaskan-based clients.
We also have ODPCP thatrequires tank inspection to an

(06:15):
industry standard as well, andthen we also sometimes have
client requirements for the STIinspection as part of their risk
mitigation, maintenance andoperation planning.
So STI SP001 is part of the STISPFA standard library and I'm
very excited to dig into thehistory and the application of
this widely used standard.
And then I'm really excited tomaybe get some clarity on some

(06:38):
things that we've noticed overthe years, that there's
questions we got, so I'm excitedto get answers to them.
So let's start with who STISPFA is.
What is the purpose and role ofthis trade organization?

So it's a merger of two trade organizations.
I think the merger happenedsomewhere around 2000.
It was the Steel Tank Institute, which had been around since, I
think, 1916.
It was actually got togetherduring World War I because tanks
were a important war material.
So a group of manufacturers gottogether to make sure that the

(07:13):
war needs were met withproduction.
But after the war obviously youcan't coordinate like that.
But they did stay in touchbecause there were rules and
regulations associated with theconstruction of tanks.
The UL 142 standard, thestandard that a lot of
shop-built stuff is built to,has been.
My earliest version is 1922.
So they had to stay kind ofinvolved to make sure that the

(07:38):
rules were consistent andsomething they could work within
.
Steel Plate FabricatorsAssociation, that's an
organization whose members builtlots of infrastructure out of
steel plate.
It was large storage tanks,certainly Pipelines, all the
other infrastructure associatedwith managing all those things.
And again, there's rules,there's regulations.

(07:59):
There's got to be consistencyin the product for just history
and safety.
And so those organizations bothtracked how things were built,
how things were produced, whatrules applied, got involved with
the standards and rules thataffect them, because you don't
want somebody writing somestandard that yeah, I can't do

(08:19):
that.
I sit on several rulescommittees.
I worked with those standardsfor years.
Now I get to help write them.
It's interesting, but you gotto make sure that there has to
be involvement by peoplefamiliar with how things are
built and especially, you know,the tank guys, the tank builders
.
Some of these companies aren'tthat big.
They really don't have enoughpeople that they can assign
someone the job of tracking that.

(08:40):
So they participate in anorganization and make sure that
their voices are heard.
We have members all over theworld.
I deal with people in Australiaand China and the Far East, not
much in Europe.
They have their own rules.
Certainly, south America,canada, the Canadian rules are
different, but there are somesimilarities but they are

(09:00):
absolutely different.
So that's kind of the historyis to stay involved.
And then we also have memberswho make the stuff that support
the tanks, the vents, thecoatings, pipe.
Every, I think the chemicalfolks and the water folks, the
water infrastructure usessimilar rules.
The standards for water tanksthey're just due to the way that

(09:31):
water tanks are used.
There are significantdifferences, but there's a lot
of things that are the same too.
So that's why the organizationis there to make sure that the
resources and the informationgets distributed properly and
people can react, and make surethat the industry can provide
the infrastructure that's needed.

I didn't realize it had such a broad
spectrum.
I've only dealt with it forsteel tanks for fuel so I didn't
realize it included water andchemicals.

Oh well, it's really interesting.
Yeah Well, maybe not up inAlaska, but down here it seems
like every municipality has awater tank, because they pump
the water up to the top of thetank and that's what helps hold
pressure constant.
You need those things water andsewer one of the first two
things you need to really have acommunity.
We do have some water tanks.

Palmer has one.
I'm not actually sure if thereare any others in the state.
The only one I know of is inPalmer.

I'm not actually sure if there are any others in
the state.
The only one I know of is inPalmer.
In cold weather locations theycan become difficult because you
don't want to end up with a bigicicle hanging up in the breeze
.
It can be done.

We also have a lot of lakes and pure water in
Alaska, so we in a lot of yeah.
We may just not need it likeyou do in the flatlands.

Yeah, and you know, and sometimes it's just a small
tank but it's on top of a hilland that gives it the grade it
needs, so it maintains pressure.

Yeah, we have a lot of those in Alaska for sure
.
All right, so thank you foranswering what SPFA meant,
because I did not know what theinitials stood for, so I
appreciate that.
So you mentioned 1916 for theSteel Tank Institute; so the STI
SPFA has been around for over100 years now

Yeah, and we have on the wall in the office.
We have what they call theCentury Club.
We have tanks that are over 100years old.
Those are water tanks Honestly,the oldest oil tank.

I know two oil tanks that are older than I've
got, one from 1914 and one from1917 that are still in service.

The oldest one I ever took care of was, yeah,
1933.
It was half riveted half welded.

We have a lot from the 30s and 40s because
they were brought up with theWorld War II mobilization.
And then they've just been inservice ever since, and all
along the different communitiesfor the Alcan and also out in
Kotzebue, Nome, A whole bunch ofthem in Fairbanks got
distributed all over the state.
So there's a bunch that were inFairbanks that got sent down to
like Kenai, for example.

(11:50):
So we have lots and lots.
In the thirties and fortiesthere used to be three that were
from the 19 teens that I knewabout, but one of them did get
taken out of service in the lastfive years but they were built
by logging companies, if you canbelieve that to serve the
logging industry in SoutheastAlaska and they were riveted
originally and then back-weldedAll right.

(12:10):
So, as you guys know, most ofour listeners work for companies
who store fuel in bulk.
They interact with your STISP-001 standard the most.
What is the ultimate goal oroutcome for this standard?
What is your hope for peoplethat are interacting with this
standard?

Well, happy, trouble-free operation of a
storage tank so that assetperforms the job that the
customer needs it to perform.
But it also doesn't become aliability during either normal
operation or even unusualcircumstances.
I always look at that thing.
I don't know, it's either likea puppy or a piggy bank.

(12:47):
It always requires a little bitof attention, but if you take
care of it it will deliver thegoods.
On the other hand, if you don'tgive it its due, all of a
sudden your several thousanddollars of petroleum product
will become tens and evenhundred thousand dollars of an
environmental liability.
Or people can get killed orpeople can get badly hurt.

(13:11):
The rules that we deal with cameabout because of events that
ended up.
You never want to end up on theevening news.
In the later 80s there was afailure of a tank in
Pennsylvania and it releasedclose to a million gallons of
fuel oil.
That got into the river and itheaded down the river and it was
affecting people's waterinfrastructure.

(13:33):
It was getting into people'swater systems.
I know a guy who he respondedto that and his job.
He got in his car and he drovedown the river and told
everybody to turn off your waterinlets so that you didn't pump
fuel oil into your water system.
And it was that event.
It was in Pennsylvania, it wasthat event that helped implement
the SPCC rule and it createdthe first tank inspection

(13:56):
standard, api 653.
And in response to that,because the government said,
either told the industry you gotto come up with a way of
inspecting your tanks or we'regoing to write the rules for you
.
But our goal is that you cansafely operate your tank in an
effective manner, that you canbe confident that you know it's
going to be there when you needit and it will respond in a

(14:18):
reliable manner.
Likewise, if it's exposed to afire, it will respond again in a
reliable manner.
It won't explode.
So that's what we're shootingfor.

That's a really good summary.
I like that.

SP001 is a minimum inspection standard.
We don't want to make it tooonerous, but you got to do
enough.
But yeah, that's what we want.
We want happy tank owners whoseasset performs the job that
they want it to perform and itdoesn't become a liability.

I really like that summary.
I feel like everyone listeningto this sometimes feels that
they look at STI as a list ofrules to follow, but I like the
overarching goal of follow theserules and your asset will
perform the way it's supposed toand maintain its value and do
what you need it to do.
I really like tying it to that.
So this is probably anotherquestion for Joe, but we do get

(15:08):
this question a lot.
STI has industry standards andthen they also have something
called recommended practices andI was kind of hoping you could
cover what the difference wasbetween those two.

And I was just at an API conference and I asked
the world's expert on that Hername is Marilyn Shores, just to
make sure I got the right answerright.
But no standard goes out fromAPI without Marilyn sort of
waving her thumb in the air.
So an industry standard is veryspecific, it's very
prescriptive, it has numbers andsections and very specific
requirements to be met.

(15:40):
Recommended practice if you'reregulated, they both can be used
to beat you over the head.
But a recommended practice ismuch more I won't say vague, but
it's more.
Here's ranges of things to meet, here's recommendations.
There's a lot more in standards.
There's a lot more thou, youshall do this, you will do this,

(16:01):
whereas practices you shouldconsider doing this, you should
look at this, these sorts ofthings.
So they're much more specific.
One can evolve into the other atany point in time, but again,
the practices are a little morevague.
The standards are much moreprescriptive.
But the regulators can pullboth out and say what are you

(16:21):
doing to address this?
And then it's up to really youto say we've done this or it's
recommended, but we don't thinkthis is a suitable
recommendation here.
But you better have somethingto back it up.
So one is much more specific,one is a little bit more vague,
but both of them have to beconsidered EPA.
If you look, they have theirdefinition of good engineering

(16:42):
practice and it's not a vagueterm.
It's actually got about a threeor four paragraph description.
And then OSHA has somethingcalled REGAGEP, recognized and
generally accepted goodengineering practice.
Same thing.
I mean you look at all thethings that those agencies can
pull out of the file cabinet andstart pointing out why aren't

(17:04):
you doing this?
So there's a wide range ofthings to consider and you got
to remember those agencies covermore than just distillate
petroleum.

Just to add on to that a little bit, Shannon,
is that the way the EPAdescribed it in the Federal
Register basically said thatindustry standards include
industry regulations, standards,codes, specifications,
recommendations, recommendedpractices, publications and
specifications, recommendations,recommended practices,
publications and other materials, and that's really all part of
what we call good engineeringpractice.
And so how we get in industrystandards, that was really, as

(17:35):
you know, brought in through theregulatory changes that
happened in the SPCC program.
So the other difference betweenrecommended practices and
industry standards and an actualregulation is it's a little bit
different in terms of howthey're actually developed.
Most industry standards likeSP-001 or even a construction

(17:55):
standard like UL-142 aredeveloped through a consensus
process with a group of expertsand other interested parties.
That differs somewhat from whatwe have in true regulations or
statutes that are written bylegislators.
So the key thing thatessentially happened in the
2000-2008 timeframe is when EPAsaid you must follow an industry

(18:18):
standard for inspectingabove-ground storage tanks or
bulk storage containers.
So it's usually once they putthat reference in there in a
regulation, you're kind of stuckto have to do that unless
you're doing something prettycrazy.
But that's kind of how it gotweaved into the SPCC program.
Craig brings up a good point.

If you look at the people that were involved in
just SP-001, you see tankbuilders, you see people who own
tanks and use tanks, you seeservice providers for tanks and
you see regulators.
So it's a big compromise and atthe end everybody kind of had
to say, yeah, this is good.
I don't think everybody goteverything they wanted, but my

(18:58):
dad's definition of a perfectcompromise is a solution that
has everybody about the samelevel of ticked off, and that's
kind of how those things work?
No, it's not perfect.

That sounds like such a Midwestern saying.

Well, it's not perfect, but we can work with
this.

Well, it goes back to the minimum of a
standard.
Right, like, the standard isthe minimum acceptable to get
the outcome.
It doesn't include all of thebells and whistles and you can
certainly add those if you wantto make sure your asset performs
better, but the minimum must beadhered to.
I appreciate both of your viewson this, because we do get a lot
of questions like oh, it's arecommended practice, I don't
have to do it, I'm like wellthat's not quite true, I don't

(19:36):
think, and so I appreciate theclarification on that and I
really like the definition thatthe EPA provides Craig about

(20:05):
good engineering practice,because that is in there, it is
100% in there.
But tying that to you shouldalso follow this for how API
says youick the best.
But there's layers ofinspection built into STI and I
think this is one of our mostmisunderstood parts by our
clients when they'reimplementing an STI program.
Could you talk a little bitabout the difference between an
owner's inspector and acertified inspector within the
STI SP-001?

Sure.
So the owner's inspector, whichis typically those are people
who are at the facility, usuallynot always, but they're the
ones performing what we callroutine inspections or periodic
inspections.
And for stationary tanks that's, under the SP-001 standard,
going to be a monthly and anannual inspection.
So you do 12 monthlies and oneannual inspection because the

(20:43):
checklists have differentcriteria in them but within the
standard itself it does talkabout the owner inspector
qualification.
So those personnel have to beknowledgeable about the storage
facility operations, the typesof AST and its components, the
spill control system for thefacility and what they're
storing.
They also need to be familiarwith how their pumps and piping

(21:05):
work and valve operations of theAST system are put together.
Now, the idea behind theseroutine inspections, primarily
the monthly and annual, is thatgetting eyeballs on an above
ground tank is always goodbecause it's above ground, we
can see it and this is reallythe first line of defense.
So the qualifications for thoseindividuals they need to follow

(21:26):
what they need to know whatthey're looking at and know
actually what's on their tanksystem.
And we know from experienceconducting training to people
writing SPCC plans that theexperience level of individuals
at a facility variesdramatically.
Now, most of the time, themonthly inspections are
relatively straightforward andyou can get these inspection
checklists directly from STI,spfa.

(21:48):
Of course they're also includedin the standard and most of
those can be done without toomuch difficulty.
I'm just speaking from apractical level here.
Probably the one that getspeople a little bit perplexed in
some cases is the requirementfor checking for water and tanks
, and maybe we'll talk aboutthat a little bit later.

Yeah, that's a whole nother.
Yeah, let's address thatspecifically.

Now, having said all that, the annual inspection
is more detailed and, shannon,you've been through the class
and we went through that inquite some detail in the
training for the certifiedinspectors, which is another
type of inspection that's doneby qualified, trained inspectors
.
And to be able to do that,those require you to actually go
through the class, take theexams, or you can also test in

(22:37):
if you're an API 653 inspector.
Regardless, there still is aminimum qualifications for that.
So that's kind of a separatething, but I would think,
generally based on the kind ofquestion you asked really is
what about these routineinspections done by owners and
what kind of training do theyneed to have?
Getting back to the annualinspection, it is challenging, I
will say, because, especiallyfor people not deep in the weeds

(22:57):
in terms of knowing what's ontanks and when we were working
with the inspection checklistjust last year as part of the

(23:18):
SP-01 revision that came out inFebruary 2024, we wanted to make
sure we were really trying toput out there.
What we're trying to do iscover all different types of
tank systems that are out there.
But it's not uncommon for somefolks to need help on doing
those annual inspections becausethey are fairly involved doing
those annual inspections.
Because they are fairlyinvolved Now in some facilities.
Depending upon where you're at,our firm will come out and do
training at a facility.
Based on that, particularly ifyou set up your SPCC plan, then
we'll be able to know what's onyour tanks and which questions

(23:39):
apply in that checklist andwhich ones may not apply Other
times.
There are tank inspectioncompanies that are retained to
do annual inspections on behalfof clients.
That's not required.
There's no certification neededto do the periodic, the monthly
and annual inspections, just aslong as you meet the minimum
criteria.
So that's the routine orperiodic inspections.
As I mentioned before, thecertified inspection is much

(24:02):
more typically infrequent but itdoes require an actual
certification from STI toperform those and much more
involved.

So, to summarize, owners representative
or owners inspectors they canbe somebody at the facility.
They could also be a thirdparty for particularly the
annual I think for most of ourclients they have.
The monthlies are performed bystaff that are operating those
tanks every day, and myunderstanding of the monthly is
it's like an early warning orearly detection system.

(24:33):
Almost everything on thatmonthly checklist is is there
something happening to this tankthat we need to bump it up the
chain?
And then same thing with theannual, sort of a more in-depth
picture on things that couldbecome a problem later if
they're not addressed early.
And then all of that issupposed to be done on a routine
basis every month, every year,and I'm glad that you pointed

(24:54):
out, craig, that there's 12monthlies and one annual.
We have some people we startworking with and they've only
been doing the annual becausethey think it's inclusive of the
monthlies and they don't needto do the monthlies.
But you have to do both.
And, joe, I cannot tell you howthankful I am that STI publishes
the monthly and annualinspection checklist for free,
available for everyone.
That has done more tostandardize this industry than

(25:15):
anything else.
Like nobody has to buy theseveral hundred dollar
inspection standard to get thoseinspection forms and it allows
us, and probably Craig as wellwhen you issue SPCCs you can
have the same form in everysingle one and you can train
people to the standard and itdoesn't vary.
When we first started and I'veonly been in business 15 years,
but 15 years ago there was a lotmore like homemade monthly and

(25:37):
annual forms that included a lotof other stuff, and over the
years I've seen it go away fromthat and having that STI
inspection record for your tank,having the monthlies and
annuals, and then your certifiedinspector needs to review those
monthlies and annuals when heor she shows up to the facility
to do their more in-depthcertified inspection.
Craig, could you talk a littlebit about certified inspection

(25:57):
though?
Maybe just in general, likewhat does a certified inspector
bring to the table?
That goes beyond what theowner's rep would.

Well, typically, a certified inspection is much
more involved in terms of whatwe'll certainly look at all the
things that are on the monthlyand annual inspection checklist.
However, certified inspectorsare obligated under the standard
to prepare their own detailedchecklist that cover not only
all of that but other aspectsthat are described in the SP001
standard.
So there's a number of otherthings that certified inspectors

(26:28):
will do, including doing,essentially, a drawing or a
sketch of the tank.
As well as identifying all theappurtenances and key features
on the tank, we'll also take alook at everything from the
foundation to the venting to thepiping, looking for evidence of
problems on the system.
And one other considerationthat's slightly different than
the API 653, which is theinspection standard for larger

(26:52):
tanks generally, is that theSP-001 standard covers not just
the tank.
It includes the stuff attachedto the tank, and so that's where
we look at things like venting,both normal and emergency
venting.
We look at valves and fittingsand anti-siphon valves and a
whole host of other things thatare, and we'll take a deeper
dive into those than what youwould do for just a quick visual

(27:14):
inspection.
Most of the certifiedinspection is visual inspection,
although it's oftensupplemented with other types of
testing.
In particular, forsingle-walled tanks and, in some
cases, double-walled tanks, wewill use ultrasonic thickness
test measurements to determinewhat the remaining steel
thickness is, but by and large,it really is sort of a much more

(27:36):
in-depth inspection that's doneby a qualified individual.
These aren't particularlycommon inspections, but they are
very valuable for facilities,not only for making sure that
they're meeting the minimumcriteria and the standard, but
even also for maintaining assetvalue and asset life, which is
something that I consider to bevery important as a potential

(27:57):
owner.

With the price of steel these days.
Yes, that is critical.
I'm just going to add one thingTanks are very valuable.

Craig hits upon an important point.
Remember, there's all sorts oftanks that fall under SP-001,
starting with it does coverportable containers, which
five-gallon drums all the way upto a 75,000-gallon double-wall
tank.
So that's where the certifiedinspector they've got to be able
to walk up and correctlyevaluate what the system is and

(28:24):
make sure everything's there.
But also, with the monthly andannual inspection, it's pretty
simple.
On a smaller tank, Some ofthese larger tanks, it can be
very involved, or involved,especially the annual involve a
trip to the top of this 30, 40foot tall tank to make sure that
the equipment up there isoperating correctly.
So the smaller tanks, yeah,those are pretty straightforward

(28:46):
.
Some of the bigger ones, or ifit's not storing petroleum, if
it's storing some funky chemical, then all of a sudden you need
to have an elevated level ofeducation, experience and
training.
So, yeah, the SBO1 standardcovers a lot of things, and so
you got to be specific enough,but also not too specific in how

(29:09):
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And if I was sitting in theowner's seat, I would also want

(29:58):
to make sure that my certifiedinspector had experience with
some of those trickier typetanks Because, like you said,
joe, a whole lot of certifiedinspectors might spend their
whole career on 20,000-gallondouble-walled tanks or less, but
that's not the same as a50,000-gallon vertical built to
a UL standard or a protectedtank or generator-based tanks.

Those create new and different challenges.

Generator-based tanks.
Let's leave those off the tablefor today.
Joe.
I can't deal with generators inthe morning, but I do want just
people who are listening.
If you're sitting in the seatof, I need to hire a certified
inspector to come out.
It would behoove you to checktheir resume and make sure that
they understand the kind oftanks that you have and that
they've got experience enough tobe able to give you, in

(30:46):
addition to the certification,that they understand the tank
and the product that you'restoring and have that background
.
Okay, so let's move on to tankcategories, because that sort of
informs how often thesecertified inspectors come in.
Could we talk about the threetank categories?
They're based on the presenceor absence of two different
things that STI has identified.

(31:07):
One is called spill control andthe other is something
everybody in the industry callsCRDM and nobody who's outside of
the industry knows what thatmeans.
But CRDM is continuous releasedetection method.
Could you guys go over whatthose two things are and how STI
defines those two and how theysort of impact the category of
the tank?

So, basically, these are two very important
concepts in the SP-001 tankcategorization scheme and the
tank categories are set up basedon risk, and it has to do with
the presence of these twodifferent, these two concepts,
including spill control and CRDM.
So spill control is a way toprevent a release of liquid to
the environment, includingadjoining property and waterways

(31:49):
, and this is your typicalsecondary containment, whether
it's a secondary containmentdike or it's a double-walled AST
or it's an open-top steel dikeor a tank that maybe has remote
impounding, which is kind of aterm that comes a little bit out
of the fire code, but thatwould be like a large tank farm.
So that's really a veryimportant consideration.

(32:12):
The other one, as you mentioned, shannon, is the CRDM
continuous release detectionmethod and that's a way to
detect a release of liquidthrough the inherent design of
the tank system.
Now it's considered passivebecause it doesn't require
sensors or power to operate andreleases are just detected by
facility operators.
Now, having said that, itdoesn't require sensors or power
to operate and releases arejust detected by facility
operators.

(32:32):
Now, having said that itdoesn't require sensors or power
to operate does not mean youcould put a sensor.
You cannot put a sensor inthere, that's even better.
But the way that the continuousrelease detection method types
are one is what we call arelease prevention barrier, and
that's a barrier that existsbeneath the tank that would, in
the event of an actual release,that release would migrate to

(32:52):
the perimeter of the tank and bedetected by operators.
An example of that might be aliner under a tank or even, in
some cases, a good qualityconcrete pad that's not cracked
and totally damaged.
That's another type of releaseprevention barrier.
Another type of CRDM is adouble-walled AST with a means

(33:12):
to check the interstitial space,or a double-bottom AST Same
thing.
Another CRDM is an elevated AST.
That's kind of another typethat's out there.
So those are the two keyconcepts in that.
So, getting back to the riskcategorization scheme, what we
consider is Category 1 tankshave both spill control,

(33:34):
secondary containment and thecontinuous release detection
method.
Category 2 tanks have the spillcontrol but they don't have a
continuous release detectionmethod.
And Category 3 tanks don't havespill control.
And so tanks, when they grow up, they don't want to be Category
1 tanks, they don't really wantcontrol.
And so tanks, when they grow up, they want to be category one
tanks.
They don't really want to becategory three tanks.
Category three tanks are kindof like the tank out in the

(33:56):
weeds.
Now under the SPCC programyou're required under that
regulation to have secondarycontainment for your bulk
storage containers.
But there are instances wherecategory three tanks actually
exist not particularly common,but the idea being that with
this risk categorization alongwith the tank size, we're able

(34:19):
to categorize these tanks andkind of make the determination
as to when this certifiedinspection is to be conducted.
So tanks that are riskier tanks, like a Category 2 or Category
3 tank, often has moreinspections from a certified
inspector and in some cases leaktesting that's required than

(34:40):
say, a Category 1 tank.
So hopefully that gives you alittle bit of window into that.
I can talk a little bit moretoo about this breakdown in
terms of where this kind ofcomes up Maybe this will be
helpful for your listeners isthat tanks 5,000 gallons or less
that are Category 1 tanks wouldtypically not ever have a need

(35:03):
for having a certifiedinspection done under the SP-001
standard.
So these are kind of relativelysmall, lower-risk tanks.
But once we're at 5,001 gallons, up to 75,000 gallons and
you're a Category 1 tank, you'regoing to need to have a
certified inspection conductedby a qualified individual about
once every 20 years, which isn'treally that burdensome, but

(35:26):
that kind of gives you the ideathat burdensome, but that kind
of gives you the idea.
However, if we were looking at,say, a 25,000-gallon tank that
was a Category 3 tank.
You may need to have thatcertified inspection done every
five years and a leak test anddo an internal inspection every
10 years.
So we do both externalinspections where we're just

(35:47):
looking at the outside of thetank.
We also do internal inspectionswhere we actually have to have
the tank cleaned and actually gointo the tank.
So what that shows is apenalization of these riskier
tank categories.

Compliance through pain points.
If you don't meet category one,then you have to do all these
expensive things that are verydifficult to do, that are very
difficult to do.
So just to summarize, we seehome heating oil tank or office
heating oil tanks as our mostcommon category three where if
it was a residence it wouldn'tbe regulated the way it is for a
commercial property.
And so they have a 500 gallonheating oil tank at the back of

(36:22):
the shop but there's nosecondary containment.
It's single walled and it'ssmaller, but it still meets the
requirement for category three.
But what I want our listeners tounderstand from what, craig,
you just said is that if you'vegot a Category 3 tank, you can
make improvements to it to makeit a Category 1 tank by
installing a secondarycontainment area and some kind
of release prevention barrier.

(36:43):
Or you could upgrade thatheating oil tank that's a single
wall to a double wall, makesure you have some overfill
protection on that tank and then, however you want to do it,
replace the tank or add thingsto the existing tank to bring it
up in category.
We also sometimes see acategory one tank downgraded to
a category two tank becausesomething like the secondary
containment has degraded overtime and it's no longer

(37:06):
functioning the way it'ssupposed to, and you could bring
it back up to Category 1 justby repairing your secondary
containment.
Does that sound accurate?

Yeah, the thing that you should keep in mind is
that the role that spill controlplays in this.
Tanks without adequate spillcontrol are, by definition,
category 3 tanks.
That's the critical thing.
So you certainly do not want tofall in that category.
The CRDM kind of blurs things alittle bit.
But when I think about aCategory 2 tank, an example

(37:35):
might be in an oil field whereyou've constructed a well and
you have some tankage there andyou've put in a line area that's
got gravel, maybe four or fivefeet of gravel on top of it, and
you've put a tank above there.
Now you will have spill controlbecause you've already got a
liner and berm system around it.
However, you may not have aCRDM because that release from
the tank.

(37:55):
You could have it go into thatgravel and you would never know
it unless you had some way todetect it.
So that's a good example of aCategory 2 tank, but there's
other ones out there as well.

Okay, so I will take my summary and back it up
and say you could have aCategory 1 tank that has
degraded to a Category 3 becausethe containment has degraded.
I will back that up.
No, problem.

Go ahead, joe.
Some of the categories alsohave to do a little bit with
history and how tank systemswere built, because there's a
lot of facilities down in theMidwest that are built on top of
clay liners.
They're built on top of clayliners and if you have a tank
sitting on the ground and itstarts to leak underneath, you
can't detect that releasequickly.
It probably won't get farbecause, hey, the clay around

(38:37):
here is pretty good, but if it'ssitting on the dirt I may not
be able to see it.
On the other hand, that sametank elevated in that same clay
liner, if it's elevated abovethe soil and I can see
underneath it, well, I'd see therelease.
That's a category one tank orit's within a containment.
I did work at, for instance,fuel terminals where it's built
in a clay liner.
If I put the tank on the ground, it's category two If I put it

(39:00):
on a good concrete pad so that Icould see the leak leaking off
into the clay.
Now I'm a category one, buthistorically the oil companies
and such would utilize earthencontainments and some of them
were pretty good.
So the category two gives alittle bit of credit towards
that.
I mean that's history.

Okay, that makes sense.

Yeah, I did some fuel terminals built in the 50s
and they had clay liners.

And in Alaska we have quite a few tanks that
were constructed in the 19-teensto 1950s.
That are just the tanks areliterally laying on the ground.
That's just how they built them.
They would compact a foundationand put the tank on it and then
liners came later.
But those tanks are typicallyAPI tanks not UL.
Okay.
So under the certifiedinspection category there are

(39:48):
three categories of tank and ifyou can get to category one and
you've got a larger tank, yourinspection burden is going to be
lower because you've made allthese improvements that have
lowered the risk for that tank.
For tanks under 5,000 gallonsyou may not need a certified
inspector at all, but you doneed to have somebody with your
SPCC determine the tank categoryand the inspection type and

(40:11):
frequency as part of your SPCC,Because a smaller tank may if
it's a Category 3 tank may havesome other additional
requirements and I feel likepeople don't take advantage of
that SPCC delineation as much asthey should.
Your SPCC should absolutelycall out the inspection interval
.
It shouldn't just say STIapplies and then leave you

(40:33):
hanging as to what it should,tank by tank.
It should go down that list andsay tank five is due for an
inspection or is not, or is acategory one or category two,
and it should lay it all outthere.
Best engineering practice.

One other thing to add to that, shannon real
quick.
One other thing to add to that,shannon real quick and this is
also available from STIs and wetalked a little bit about this
during the most recentdiscussion for SP-001, is that
there's a document known as theAST record in the SP-001
standard.
Yes, it's in the back and Iwould encourage those that are.
That's something that's arequirement of the owner to fill

(41:07):
out and that actually documentsa lot of valuable information
for the owner.
Now, in some cases this may besomething with some firms.
They might fill that out aspart of an SPCC plan preparation
that goes through and actuallydocuments what the tank category
is and provides a lot ofvaluable information.
And for those that arelistening that might be

(41:28):
responsible for tank farms or afleet of tanks, that's another
good way to use that informationto be able to develop almost
like a matrix, if you will, ofyour tanks and when they might
be due for inspections.
Of course, that informationshould be in your SPCC plan, but
regardless, epa was veryinterested in enhancing the use

(41:48):
of that AST record as makingthat more widespread.
It's a very good document andit is available for free at the
STI website along with theinspection checklist, so that's
available for people as well.

We recommend people do the AST record when
they get a tank installed aswell, because oftentimes some of
the data that they have atinstallation gets lost over time
and that.
Ast record can capture it yeah.

Sure, as someone who wrote SPCC plans, you have
to be very thorough and verycareful in documenting
everything and putting all ofthe information.
There's something calledWaller's rule and it says you
never make a regulator think.
Don't make them wonder what'sthe inspection cycle?
When was this tank put in?
What kind of tank?
No, no, no.

(42:32):
Make it perfectly clear.
The SPCC planar should make itperfectly clear.
It's this type of tank.
It was installed at this date.
It was last inspected on thisdate.
Here's the cycle, because oncethey start asking questions and
they dig things up and so makeit perfectly clear as to what is
required and that AST record,the EPA was involved and they're

(42:54):
always involved in SP-001.
In fact, it was Mark Howard atthe EPA that dreamed up, said
the Steel Tank Institute shouldcreate a standard for their
shop-built tanks, because API653 wasn't the right standard
for shop-built tanks, and so Iconsider him the godfather of
the SP-001 program.
But he said that he wants tosee an AST record for every tank

(43:19):
in an SPCC plant.
So I guess that would be goodadvice.

Well and, as you both know, there's a wide
range of complexity.
You know the SPCC product.
Depending on who is doing thework for you, you can get a wide
range of outcomes.
And so what I'd like most ofour listeners who probably don't
write their own SPCCs, but theycan certainly grab their SPCC
that does not have a specificinspection schedule listing the

(43:50):
class of their tank and when theinspections should occur and
what type of inspections theyprobably need to consider that
in their next RFP when they askfor someone to do the SPCC, they
want to make sure that that'sincluded in that product for
them.
Okay, so we've covered tankcategories, certified inspection
intervals.
Let's talk about being a tankowner and you've received a

(44:11):
report from a certifiedinspector.
What should you pay mostattention to in that report?
You've got a tank that's over5,000 gallons in size.
It's been 20 years.
It's time for that certifiedinspector report.
They come and do the inspection.
When you get that report back,what are you looking for?
What's the high priority itemsin there?

I can probably address this one, joe, because
we do run into this a lot.
I mean, just like Alaska,california has its own
above-ground petroleum storageact, its own program.
So this concept of having thesecertified inspection reports is
not new.
It's been in place for over 10years, so they are more commonly

(44:48):
found.
This is becoming more and moreimportant for owners because
these are typically reviewed aspart of an SPCC inspection by
EPA and if you have your stateorganization as well, so this is
pretty common to have themreview those reports.
One of the main things, the maintakeaways about this, is that

(45:09):
if there are findings in yourreport and in an SP-001 report,
we'll typically have requiredactions.
Those are the ones that thefacility owner needs to take to
conform to the standard.
We also typically haverecommended actions, and those
are also valuable, but those areones that we may be thinking
more about asset life or othertypes of things to ensure a safe

(45:32):
and compliant operation.
But what we're doing withcertified inspection reports is
determining if these tanks aresuitable for continued service.
So, getting back to the issueof the required actions and this
is something that owners shouldconsider very carefully is that
some of these examples of theseinclude tank that does not have

(45:52):
, that has inadequate emergencyrelief venting that's considered
a safety issue.
Tanks that show visible signsof leaking from the tank or
anything connected to the tankthat can't be resolved without
taking the tank out of service,or damaged or non-conforming
electrical systems in hazardousareas that pose an imminent

(46:12):
ignition source.
Now there are otherconsiderations in certified
inspections where we havecriteria in the standard where
we're talking about minimumsteel thicknesses and these
minimum steel thicknessesactually go back to the tank
category, not to get too deepinto the weeds on this.
But there are cases where wehave, if minimum steel

(46:35):
thicknesses are not maintainedconsistent with the standard,
they are required to eitherrepair or replace the tank.
So those are required action,like I said, recommended actions
.
Those are the ones that areprimarily for asset management
and other good practices.
What we've seen a lot now ishaving agencies closely review

(46:56):
these inspection reports andmaking sure that owners are
getting good quality reportsgoes a long way, because both
Joe and I occasionally get callsfrom California regulators
saying Joe and I occasionallyget calls from California
regulators saying, hey, thisperson decertified inspection
but it's not meeting thestandard requirements as spelled
out in SP-001.
So that's kind of the trickypart.

(47:20):
That's one consideration.
Back to the owners, if theinspector report says there are
some required actions to be doneand the owner does not
implement those required actions, the owner could be at risk for
not essentially implementingtheir SPCC plan, and I've seen

(47:41):
EPA and other agencies use thisprovision during enforcement
proceedings.
So that's something veryimportant for owners to be aware
of that.
Once it's brought up there,it's part of your compliance
program.

What's the timeline under the SPCC?
Because we definitely have ourclients and listeners.
Once you've identified aproblem, how long does the SPCC
give you to fix it?

The SPCC itself would give you a certain number
of months to update your plan.
However, I think the conceptthere's kind of a practical
level to this.
If your tank is leaking product, I think that's a short
interval right as soon aspossible.
Yeah, I think the agencies toowould also take a look at if is

(48:25):
an owner making progress towardgetting things done.
So that's an enforcement matterthat I can't really speak on
because I'm not a regulatoryagency, but I know from
experience of working with themthat it goes a long way in
trying to show some diligencefor sure.

The takeaway, though, is you can't receive the
report and do nothing.
You need to look at therequired stuff and determine if
something needs to beimmediately taken action Like
I've got a leaking tank I didn'tknow about and then you also
need to look at all the otherrequired pieces and start having
a plan for getting themcorrected as soon as you can,
and then have that plan in place.
Even if you can't do it rightall right away, at least if a

(49:04):
regulator shows up, you can saywe've identified the problem,
we're working on a solution andwe've got a plan forward.
You can say we've identifiedthe problem, we're working on a
solution and we've got a planforward.

Often I've seen where the regulator wants a
schedule.
If you have a good reportthat's clear on what they found
and what needs to be done,that's a good start, okay, and
now let's look at what needs tobe done.
And well, here I'm planning ondoing this.
Here's my schedule, becausesometimes I've done it, where
we've inspected the tank, it'sgot a couple of modest issues.
You know what?
I'm going to replace that tank.

(49:30):
So I'm going to do these fewminor things and in eight months
I'm going to have a brand newtank, because I wanted a bigger
tank anyway, or something likethat.
So, if you have a clearschedule but bear in mind,
they're going to hold you to it.
If you have a good history andyou've always followed up before
, yeah, they're going to cut youa little slack.
If you've told them things thatended up not being true in the

(49:51):
past, they're going to be allover you.

Yes, the relationship with the regulator
is super important.

It is good that a report should have a clear
conclusion, a clear statement Isthis tank suitable for
continued use?
Because, as Craig pointed out,if you have an immediate problem
, the SB-001 says, well, shutthe tank down and fix it now,
don't wait.
So it's kind of how bad is theproblem?
What are the circumstances?
You know, I got to paint mytank, but it's late November.

(50:19):
That's not going to happen fora while.
But have a plan, have aschedule.
That's what the regulator wants, because they're going to go
after the people that are doinganything.

They're not going to go after the people
that are doing anything.
They're not going to go toohard after the1 that address
finding and removing waterintakes, and all three of us in
this interview.
I would like to have you guystalk a little bit about water
and why it's such a big part ofthe STI SP-001 for our listeners
.
So why is it so important?

(51:03):
Why do we address waterspecifically at the monthly, the
annual and in certifiedinspections?

Carbon steel is a great material to work with.
It has flexibility, it can bewelded, it can be formed, it's
very durable, but it rusts whenit's exposed to water.
So water is the enemy.
We have a kind of a statementat STI that if you have a
properly built and operated tank, if you keep clean product in

(51:30):
the tank and paint on theoutside, its operational life is
indefinite.
But let junk build up aroundthe perimeter and hold water
against it or let water sit inthe tank, you could be gone in
18 months.
Some of these smaller tanks thatare thinner, so the presence of
water will greatly affect, arethinner.

(51:53):
So you know, the presence ofwater will greatly affect the
predictability and thereliability of your system and
we want you to have a reliable,predictable system.
And then we also have the issuewith microbial growth, which is
just gets more interesting withsome of the new fuels out there
.
But it really can't happenwithout some water.
So keeping your fuel clean anddry helps prevent microbial

(52:13):
growth.
And something I've noticed iswe have a lot more tanks that
get filled up and they just sitwith product.
You know those generator-basedtanks, those backup.
If you have a constant turnoverof fuel, that will address some
water issues.
But if you have a tank that justsits well, now you've got a
collection point, but, yeah,water in a tank, it is going to

(52:35):
adversely affect the tank fromthe inside.
Or if you let water and junkbuild up on the outside, it'll
adversely affect Just water andcarbon steel not the best
friends.
That's kind of the end thing.
And then it can mess up yourfuel.
But bear in mind, in the SPOand standard, I'm not taking
care of your fuel, I'm takingcare of your tank.

(52:55):
So, as long as your fuel isn'tattacking the tank, if you're
really counting on that fuel ina tight spot, you want to be
inspecting it even more often,because I have seen tanks where
the tank was okay but the fuelinside the tank wasn't worth it.
And when they you know,remember an airport I worked at
they had a power outage.

(53:16):
Out of seven generators, onestarted, four or five of them
were frozen solid, one was outof fuel.
But still, here you are,finally need it and nothing.
Yeah, so yeah.

Could you guys talk about microbial infection,
if you will, Because oncemicrobial corrosion occurs it's
pretty difficult to get out of atank.
Is that correct?

That depends on the tank and the product being
stored.
There are some things going on.
I mean the issue of water.
Some of the new fuel blendsdon't have certain things that
were in the older fuel blends,sulfur being one of them.
It helped keep some of themicrobes in check.
Some of the biodiesel products,which maybe you don't use so
much way up in the north, butthose add some things.

(54:01):
The other one is and thishappens in the process where
fuel is transferred and movedaround you can get traces of
ethanol in, like fuel oil, justbecause it was in the same truck
that held.
Well, ethanol is bug superfoodand so you get a little just.
There's a great report thestate of Georgia did the guy's
name is David Howell, he did areport on this and just traces

(54:24):
of ethanol and traces of watercreate circumstances that you
wouldn't expect to occur, butjust can, and all of a sudden
bugs start growing.
But yeah, another thing to bearin mind is, once you identify
microbial corrosion, well, nowyour fuel's compromised and you
got to be careful what you do tothe fuel, because you don't
want to add anything that'sgoing to make the fuel now be a

(54:46):
problem for the user.
When I ran into it.
I always got my fuel supplierinvolved and say here's my
problem, what do I do?
The fuel is warranted by themanufacturer and if I start
dumping things into the tank,there goes my warranty If my
additive screws up my customer'sfuel injection system.
So be careful, what you add toyour tanks, you know, got to get

(55:11):
rid of the water Absolutely.
Maybe you need an additive,depending upon how much fuel you
have.
Maybe you empty the tank andstart over again, but bigger
ones maybe you can't do that.
You have to kind of address itbased on your circumstances, but
you have absolutely positivelyhave to address it.
And some industries a littlelike the aviation industry, they

(55:31):
go nuts on water Daily waterdraws for every tank.
You laundered a few jets intopeople's backyards.
You get noticed, you know.

But that's the risk factor.
Right For aviation, it's a highrisk situation.

So they've upped it.

So, yeah, water check regularly, check, often,
maintain the equipment, theplaces on top of your tank,
because when I find people witha water problem, we say, well,
where is it coming from?
You know, emergency vent, someother fitting, maybe the roof's
draining.
When it's raining it's landingon top of the tank and you know,
because the stuff's usuallyweatherproof, but you deluge it

(56:07):
enough, you can overcome it.
So find the the source too.
But yeah, definitely don'tignore water.
It'll bite you in the backsideand it'll do it at the worst
possible time.

And it deteriorates your acid.
If you just leave it and leaveit and leave it, it's just going
to continue at it.
So, just like a fire, formicrobial infection or microbial
corrosion to occur, you have tohave steel, fuel and water,
because those three togetherhave all the right pieces for
the bacteria to thrive or themicrobes to thrive.
One other thing to add to that.

Shannon, is when we run into clients or
facilities that have concernsabout water and tanks.
One thing that is done widelyat least in the lower 40,
probably also up in Alaska isdoing fuel polishing and having
someone come in and polish thefuel and that's a good time to.
You can certainly also havemore formalized ASTM testing

(56:58):
done of your fuel to determineif including some of the
microbial side as well,Potentially using biocides as
well, is another one, becausethese microbes are ubiquitous,
so it's just not like it onlytakes parts per million of these
microbes to be able to get yougoing.
But trying to kind of have agood program for fuel quality is

(57:19):
something important,particularly for critical sites,
whether it's a data center or ahospital or an airport or
whatever.

We do have a recommended practice on keeping
water out of the tank.
I think it's R111.

We will make sure to put that in our show
notes.
Yeah, water management ispretty important, and I think,
craig, your point about howcritical this fuel being
functional is is well taken,because a lot of our clients
have emergency generators.
They have their own fuel tanks.
That they're like.
We have a lot of fishprocessors.
They're making their own powerfour or five months of the year,

(57:54):
but then the other six the tankis just sitting, and so having
water management occurthroughout will just help
preserve your asset of the tankbut it'll also help preserve
your six to $7 a gallon dieselasset as well.
So one last like seriousquestion because I have a
lightning round plan for youguys up next, but this is

(58:15):
something we get a questionquite a bit from our owners is
does an STI SP001 inspectionneed to be performed at tank
installation?
Because there's one due every20 years but the regulation
isn't super clear about.
Does it need to be done at thebeginning as well?
Does it need to be a kickoffinspection or is it just once

(58:35):
the tank's installed?
Then 20 years.

No, it does not need to be done.

Do you want me to take?

this one, joe.
In fact the SBO1 standard saysthat before an inspection should
be done.
It's one of the early items.
It's in Section 1.
I think it's 1.
Let me even look that one upfor you because it's an
important one and there is someconfusion.
I have done commissioninginspections.
1.2.4 says the owner isresponsible for making sure that

(59:02):
the system is designed andinstalled properly.
You know SP-001 is trying toassumes that the system is
properly installed and is tryingto identify degradation due to
time, use, exposure and theother thing too, because of all
the wide range of systems thatcan be, this can apply to an

(59:23):
installation inspection.
You know it has to make surethat all the components that are
installed are installed permanufacturer's recommendations.
The storage tank which ourmembers built, that comes our
STI storage tanks come withdocument R912 on installation
instructions on how to properly,you know, make sure the tank is
on a good foundation, confirmthe integrity of the primary and

(59:44):
secondary tank at the time ofinstallation.
You know, make sure everythingis in order with the new tank
before the first drop of fuelhits it.
But you have piping componentsinstallation.
You got to make sure you gotall your setbacks in order.
Are you far enough Because it'sa lot easier to do it now than
later, so those sorts of things.

(01:00:06):
So an SP-001 inspection itfirst starts at the end of the
first month with the firstmonthly inspection.
Certainly any brand new tanksystem should pass the basic SPO
and inspection with flyingcolors.
But you really don't need to beusing an ultrasonic thickness
tester on a brand new tankbecause two or three people have
already done it before you.

Craig Fletcher (01:00:24):
Yes.

Joe Mentzer (01:00:25):
Yeah so.

I can tack on that a little bit too, shannon
is that we run into this issueas inspectors getting requests
for doing certified inspectionsfor initial commissioning, and I
think part of the reason isseveral fold.
But the standard itself whattriggers that 20-year inspection
date, if you will, is theinitial service date.
That's the date and whenproduct first hits that tank.

(01:00:48):
So that's our clock start, ifyou will.
And it doesn't matter if thetank was used somewhere else and
then brought to a new site.
The initial service date iswhen that tank first had product
, even if it was at another site.
So that's how that 20-yearcycle, or whatever the frequency
is, starts.
But getting back to the issuethat we run into with people

(01:01:08):
asking for certified inspectionsupon initial commissioning, I
think it goes back to a coupledifferent things.
One some owners want peace ofmind that the contractor has
actually installed the systemconsistent with fire codes and
other things.
Some states, includingCalifornia, don't have a
statewide installation permitprogram for ASTs.

(01:01:30):
That's kind of left to thelocal jurisdictions.
But really the standard wasn'tdeveloped with that in mind.
But I can see why people wouldactually request it and it can
be a contractual thing.
We've got some federal agenciesasking for this as part of that
, and it's probably becausethey've been burned in the past
by having stuff that gotinstalled improperly that they
find out later.

(01:01:50):
We're also aware that insurancecompanies are calling for
certified inspections of tanksand that's probably a risk
reduction type approach.
So it may be more of a peace ofmind thing as opposed to and
that's probably a risk reductiontype approach.
So it may be more of a peace ofmind thing as opposed to
something that's mandated in thestandard.
The beauty of this SP-001 is itextends out beyond the tank so
we get a chance to take a lookat stuff like venting and

(01:02:12):
anti-siphon issues and otherthings like that.
But there is no hard and fastinitial certified inspection and
install required.

Shannon Oelkers (01:02:21):
Yeah, we have definitely been seeing an
increase in requests for it.
I also have seen they want adocument that says the next
inspection date on it that theycan refer back to for their
databases or their tankinspection matrix, because
they're managing hundreds oftanks, right, sure?
And when you have it installedby a contractor you're not

(01:02:41):
necessarily.
You might get a job book butyou don't get a cover sheet that
says this tank was installed onthis date.
It's a class one tank and itshould be inspected in 20 years.
They're saying they met theinstallation standard, but
they're not necessarilyprojecting out that inspection
date.
So I've definitely seen thatcome across.
In addition to what you said,craig, as far as peace of mind,
especially with the DOD, we'vehad a lot more requests from the

(01:03:02):
DOD to do some kind of initial,especially for tanks that maybe
are older, like maybe 10 or 15years, and they're moving them
from one place to another.
They want to make sure the tankis good to go with the UT
thickness and everything else,even though it's not necessarily
time for it, because they justwant to make sure before that
they put it into serviceeverything's good.

I certainly did lots of inspections of tanks
that my clients own and wererelocating and before they moved
them, hey, let's make sure thatwe need to relocate this to a
new spot and not to thescrapyard and that's definitely
a good.
But, yeah, on brand new system,I work in a state that has a
commissioning process that hasseveral inspections and a long

(01:03:44):
litany of tests that we do priorto the first drop of fuel
hitting them, and they're muchdifferent than SP-001.
And so, as far as commissioninggoes, I would recommend more
steps on a commissioning processthan are listed in the SP-001
standard.
There's a lot more, yeah.

Alaska and the state of Washington.
I do not believe.
I don't think the state ofWashington has a commissioning
process.
I know Alaska does not.
It's just the Wild West up here.

And, as you said previously too, you want to make
sure you capture certaininformation at the time of
startup, because the further youget away from startup, the
harder it is to track that stuffdown.

And that was part of our commissioning
process was putting together allof the records and handing them
to the owner, so that, ok, now,in five years, when someone
asks here's all this stuff tohave that information in it too,
because oftentimes job booksare just a collection of really
badly scanned weld seam reportsand liner installation reports

(01:04:45):
and we're encouraging them toinclude an AST record and an
installation verification signoff by an engineer or somebody
knowledgeable, up to andincluding a certified inspector,
just something to make thatrecord usable in the long run
for the life of that team.
Okay, so those were all of myquestions that I had for you

(01:05:06):
that were sort of more in depth.
If you guys are up for it, Ihave a lightning round of just
things we find on the monthlyand annual that we get questions
about a lot that I would dearlylove some clarification on.
The first one is cracks inconcrete foundations or
containment walls.
And maybe because we're inAlaska, we see, you know we have
earthquakes and we have harshenvironments, but is it any

(01:05:27):
crack whatsoever or is theresome leeway for minor small
cracks?
I mean, like, where do we fallon?
Are there cracks in yourconcrete foundation or concrete
containment?

I can try and address this one, because we do
talk about it in the STI class,but the standard itself is
silent on that issue to myknowledge, and this issue should
really be addressed by the SPCCplan writer.
This kind of falls back intotheir world and so they're the
ones making the call as toremember that under the SPCC
regulation the containment isrequired to be sufficiently

(01:05:59):
impervious to contain dischargedoil until it can be cleaned up.
Having said all that, I cangive you some general guidance,
not from the SP001 standard, butjust some general concepts out
there.
But just remember that concreteby its very nature is going to
have some cracks at amicroscopic level.
That's just how it works, right.

(01:06:20):
But it doesn't mean it's notsuitable for containment.
But remember that containmentneeds to be constructed to good
engineering practice.
So that means if we're puttingin concrete it's going to
reinforce concrete.
It's not just going to behollow block masonry walls.
We see a lot of masonry wallswith grout failures that need to
be addressed.

(01:06:41):
So there are provisions underNFPA 30 for containment to be
solid masonry, not just hollowmasonry walls, if that's what's
to be used.
So that's a separate fire codematter.
But we run into that a lot andthat's almost destined to fail.
So that means that you're goingto typically have rebar and

(01:07:01):
mortar inside of the actualhollow blocks if that's what
you're deciding to do.
Just some other generalguidance.
Like I said, this is not part ofSP-001.
But if your containment is notholding water consistently, it's
probably not going to hold oil.
I mean not to be CaptainObvious about it, but you know

(01:07:22):
that's sort of the basic.
Another one is if you havecracks and you have vegetation
growing up through the cracks,that also seems like it's not
going to really pass the laughtest, gotcha, and then other
ones that we think about, if onour company side, is that if
you've got cracks that showlateral or vertical offsets that

(01:07:42):
imply structural problems whereyou're having failing, maybe
due to subsidence or frost,heave or other things, those
need to be addressed by the planwriter.
Overall, hairline cracks don'tusually cause problems, but
those should be monitored.
Where we start kind of drawingthe line a little bit is
somewhere between maybe thethickness of a credit card to a

(01:08:06):
sixteenth of an inch, which isabout the thickness of a quarter
.
Those should be addressed,those that are getting up to
that, the thickness of a quarter, which, like I say, is about a
sixteenth of an inch.
Those are definitely worthwhileto be looked at.
Those should be monitored and,as needed, addressed by the SPCC
plan writer.
Just remember, they do makecrack gauges out there that are

(01:08:27):
relatively cheap that facilitiescan use to track whether
they're actually having an issueor not, whether your cracks are
growing.
That's just some generalguidance.

It's not part of SP001, but it's just a
thought it does come up a lotwhen we do the training for
monthly and annuals, though, theguys are like well, we have
cracks and I was like well, yes,but they need to be bad cracks,
Then how do you tell?
But I like the tools that yougave us.

I'll add two things .
First off, when building thereare standards.
The American Concrete Council,I think I can get you the
reference.
There is a standard forconstruction of containments for
hazardous materials.
That one should certainly beconsidered.
A lot of the concrete guys Iworked with would incorporate
mesh into the top of theconcrete.
It's just below the uppersurface.
That helped minimize cracks, orat least in the Midwest we say

(01:09:19):
there's two kinds of concreteConcrete that has cracked or
concrete that will crack.
And the last one is if you haveto look at the crack inside,
gee, is it leaking or not?
You probably would go back toWaller's rule Don't make them
think, just get out.
You know, seal them up.
It's easier that way.

Seek a flex for everybody.
Seek a flex, all right.
Second, lightning round.
A lot of our tanks, you knowthey've lived a little.
They have dents or creases orother kinds of like stable marks
on the shell.
They got kissed by a loaderright before installation.
You know something happened.
How do you address those in theperiodic inspections?

(01:09:54):
Cause there is, there is aquestion that says are there any
on the tank?
But some of these are stableand have been with the tank for
years.
They don't affect the integrity.
How do you handle?
that under the STI inspection.

Well, normally, in those cases when we often see
denting, for example, that inour experience, appears to be
often associated more withventing problems and venting
insufficiency.
Why is it there?
Yeah, tanks can't take vacuum.
They cannot withstand very muchvacuum, and so that's really
why you will occasionally seedenting on tanks.

(01:10:29):
Now, if somebody ran into itwith a loader, that's kind of a
different matter, but what wetypically do is to try to
monitor those areas and maybemark off where that dent is to
see if it's actually changing.
However, if there are severecases where denting is occurring
, that's where you're going toprobably need to have a tank
engineer involved to be able toreally look at that further.

(01:10:51):
For minor denting, it'sprobably something you should
just be monitoring during yourmonthly inspection.

You got to figure out.
Why is the dent there?
I've seen some dents.
Why is that?
Oh, because it didn't make itunder the bridge when it was on
the back of the transport truck.
Yeah, that's a bigger problemYou're going to be looking at.
Did you take the carbon steelpast its plastic limit and start
to deform it, stretch it, thinit, crack it?
Or is it just where carbonsteel can flex in and out a

(01:11:16):
little bit?
Like Craig said, at some point,you need a tank engineer and
you really need to know why isit there.

I think for the purposes of this.
We all know why it's there.
It's been there since the tankwas installed.
The tank is 15 years old, it'snever changed and maybe you guys
can tell me.
What I have advised in the pastis you know how you can take
the monthly or the annual andyou can enter in text in the

(01:11:43):
comments.
I would just enter the you knowcrease on west shellhead or
whatever, 18 inches long, stableor something.
So you are acknowledging thatit's there, but it's not
something that appeared prior tothe last month and that makes
you want to look and see ifthere's a venting problem.
If we know it's there and it'sstable, just indicate it, put it
permanently into the inspectionrecord for that tank and then
you can just keep checking off.

(01:12:04):
Yes, it's fine, you don't haveto keep writing it in every
month or every year.

And when I ran into those informal inspections I
was looking for if the steelthinned or if there was a hard
crease in the tank, those sortsof things, and those would catch
more of my attention in thetank, those sorts of things, and
those would catch more of myattention, gotcha?

Okay, cool.
Let's talk about tank grounding.
We get this argument quite abit.
If there's no grounding strapon your standard UL 142
constructed tank, could the tankstill be grounded?
And how do you know?

So that's kind of a question that's a pretty
site-specific one that mayactually require an evaluation
by a grounding expert or anelectrical expert.
Now, if a tank's located on aconcrete pad that's not directly
in contact with the earth, it'sunlikely that you would
probably have direct connection.

(01:12:55):
You could claim the tank wasgrounded.
Have direct connection.
You could claim the tank wasgrounded.
Remember that for grounding andbonding, what we're trying to
do, there is dissipation ofstatic charges that develop
during fuel transfers and it'sparticularly critical for jet
fuels and other similarnon-conductive liquids.
There is also a school ofthought that some of the
grounding and bonding doesprovide some lightning

(01:13:17):
protection, but that's kind of aseparate whole specialty so I
don't really can offer anyopinion on that.
But some folks say that tankslocated directly on the ground
itself may be grounded.
But I think that's somethingthat you probably have to prove
out somehow through conductivitytesting or some other way to do

(01:13:37):
that or getting an expert inthat field involved.
That's the best.

Or grounded the normal way.
So compliance through painpoints yes, yeah.

It's not rocket science to do grounded.

We get a lot of it's grounded.
It's grounded and I'm like, butfor me to check this off as the
certified inspector, I need toknow it's grounded and I can't
tell right now.
We get a lot of the pipingsgrounded and it's connected to
the piping, which may or may notbe true as well.
Joe, do you have any thoughtson this one?

Well, that goes back to that Waller's rule thing
.
If grounding is required, itshould be obvious.
There are points, normally onsmaller tanks you can tie in.
There's usually a lift lug onthe tank and tie in.
There's usually a lift lug onthe tank and that's a good place
to either put a you know,either a clamp to the lift lug
or drill a quarter inch hole andattach a ground strap there.
Certain tanks don't needgrounding.

(01:14:28):
Certain chemicals they don'trecommend grounding, although
petroleum it generally is.
But in my mind it was always.
It should be pretty obviousthat there is a ground strap
there, because if there wasn't,then the only way to convince
the inspector was to have anelectrician confirm it's
grounded.
And then next time, well, canyou confirm it again?
It's like just put the groundstrap on and make it blatantly

(01:14:49):
obvious that it is grounded,path of least resistance.

Yep, we also see tank grounding straps that
get caught by snow plows andstuff quite a bit because
they're under.
So I've seen grounding strapsthat when I pull them up they
just come out of the leaf litter.
They've been severed at somepoint.
Surprise, okay, thank you forthat.
Visible signs of coding failure.
As you know, I work you know,pacific, northwest alaska we
have a little more severeenvironment than other places.

(01:15:16):
What would you consider to becoding failure that needs to be
documented on the periodic forms, like when do we get there?
Where does STI or common sensesay that we should do it?
Because a lot of our tanks theyalmost all of them have coding
failure in some way.
I'll be honest.
So, when do we get to the pointwhere we would start monitoring
it and documenting it?

Well, I think the key thing with that, shannon
, is that the definition ofcoating failure in SP-001 is
significant peeling, cracking,spalling, pitting of the coating
paint or lining on an ASTresulting in the exposure of the
metal surface and corrosion ofthe tank shell.
So you can lose your.
Maybe you have a primer coat.

(01:15:58):
You may have a paint coat ontop of that.
You could theoretically losethe paint coat but still have
the primer coat underneath,which would not be under this
definition of coating failure.
However, at the point you'rebasically having, you're seeing
rust on the tank.
That's the time that wherecoating failure is defined, that
under the standard Okay, isdefined under the standard.
So when we do a formalinspection right, a certified

(01:16:20):
inspection we really evaluatethat, because what we're doing
there is we're using toolsultrasonic thickness testing to
quantify the remaining steelthickness of the tank.
So that's really it may lookbad, but it may be somewhat
trivial in terms of the actualintegrity of the tank itself.
However, that definition ofcoating failure is in the

(01:16:42):
standards, so that kind ofspeaks for itself in that regard
.
Remember too that it's usuallya lot more cost-effective to
address coating failures in spotlocations than it is to go in
and completely redo a tank,which is a long, involved
process to do it right for acomplete tank coating

(01:17:03):
replacement.

And when I'm doing an inspection I really got to.
The first thing people see whenthey walk up to a tank is the
paint.
I've installed lots ofbrand-new tanks and it gets
delivered and the first thingthe guy who bought it oh, how's
the paint look.
So, any minor blemish on thepaint?
I almost have to put it in theinspection report because my
customer is going to see it andif I don't write it down, well,
what does that inspector know?

(01:17:25):
He didn't see this in airquotes obvious issue.
So yeah, paint tends to getbrought out.
A lot Paint.
The coatings industry hasadvanced a lot in the last
several years and those guyswill tell you that when you
start to see some rust, it justmeans that the paint in general
is coming to the end of its life.
So bear that in mind.
Unless there's some physicaldamage to it and Craig hit the

(01:17:48):
nail on the head take care ofthose minor issues quickly with
just a little bit of cleanup anda coat of paint and then we
won't call them out.
But yeah, you can't ignore rusttoo much.

No, no, I think it's just the reality of Alaska
is the environment's harsh.
So coating failure is justsomething that we have and it's
got to be.
But what I want our listenersto understand is that you should
be monitoring it anddocumenting it in the monthlies
and annuals, because that givesyour certified inspector clues
to how long the problem has beenin place, which can affect

(01:18:23):
corrosion rate calculations orsuitability for service, like if
it just started happening acouple months ago and is
advancing greatly.
Something's changed about thattank and we need to figure out
why, and it may be that thecoating has come to the end of
its useful life.
It may be that somethinghappened to the tank.
It may be that the tank has,you know, changed service and
something's changed, or it's hadan event I don't know something

(01:18:44):
like where they power washed itbut it was too high a setting
and it damaged it, somethinglike that.
Okay, I have one last lightninground question for you.
A lot of our tanks that aredouble walled, they're outside
of secondary containment.
They have overfill preventionvalves installed in line with
the fill connection, becausethat's very efficient when less
appurtenance that you need tohave.
There's a monthly requirementto tell that they're in good

(01:19:08):
working order.
How do you do that if you'dhave to disassemble the whole
tank?
And I was always taught not tofill the tank up and pop it
right.
You're not supposed to fill thetank up and overfill it
essentially so that you can tellthat it's working.
So do you have any tips for howto address that on the monthly
for those of us with inlineoverfill prevention valves like

(01:19:28):
floaters?

There are a rare few overfill prevention valves
like you're describing thatactually can be tested
externally, and some of thesehave a cable that can be used to
manipulate the float inside thevalve.
But these are not very commonand they're more expensive.
But you're right, most overfillprevention valves require
complete removal to actuallyperform, to confirm that they're

(01:19:53):
in good working order, and thatis not something that owners
even certified inspectors forthat matter typically do.
This is the work of typically apetroleum contractor or some
other mechanical contractor toperform.
So not only would they have toremove it, check the float,
they're going to have toreassemble it and put it back in
and pray that they get theright setting on the tank level

(01:20:16):
so it can work right.
So, other than taking a look atthe top fittings on the tank
where that valve comes into thetank for stuff like damage or
corrosion or if it's leaking,there's very little you're going
to be able to do with those.
Having said all that, it'simportant to remember that
overfill prevention valve isyour last line of defense when

(01:20:38):
it comes to preventing anoverfill.
So you should be having gaugesand high-level alarms on those
tank systems.
Those are your first lines ofdefense.
Owners should not be relyingsolely on an overfill prevention
valve as their sole means foroverfill prevention.
That's kind of the takeawayfrom that.
Normally, I have you know, insome places in California the

(01:20:59):
fire marshal will be there whenthey do the first fill and they
want to see that overfillprevention valve actually
operate properly.
Sometimes it hasn't beeninstalled properly and there's
problems.
So overfilling tanks is nothingI ever, you know, intentionally
recommend anyone to do, but itis one that's very difficult on

(01:21:19):
these valves that have no meansof external checking.

So I'll add several SGI members manufacture those
valves.
The regulators I've dealt withhave said follow manufacturer's
recommendations.
So look and see what themanufacturer has, because that's
also the club, because that'san appurtenance that gets
installed by somebody else onthat tank.
But those manufacturerinstructions are what the club

(01:21:43):
that the regulator is going tobeat you with.
The component manufacturershave gotten much better now that
they recognize that there canbe maintenance requirements
there Craig pointed out.
Yes, there are some that can betested, so that option exists.
So you know, make sure youfollow manufacturer's
recommendations and maybe askwhat equipment's being installed
and make sure that it's amaintenance schedule you can

(01:22:08):
live with, because some arebetter.
Especially, I see this ongenerator base tanks.
Those units come out.
They got the cheapest equipmentimaginable, trying to keep the
price of the whole overall, andyou end up with this junk that
ends up being more grief thanit's worth in the long run.
You end up fighting it and thenreplacing it at a significantly
more expense later with abetter component.

(01:22:30):
But manufacturer'srecommendations the good
manufacturers list them on theinternet so you should be able
to get yourself a copy.
So that way when the regulatorasks, yep, here's the
recommendations, here's what wedo, that is really good advice.

Thank you for that.
Okay, Does STI SPFA have anyfree or low cost resources for
our listeners, Joe, that want tolearn more?

Oh, certainly we have lots of webinars on very
good, very specific tank-relatedsubjects.
Our website is wwwstisbfaorg.
I mean I did a webinar earlierthis year on generator-based
tanks.
We've got one coming up on tankappurtenances, stuff, on

(01:23:15):
coatings.
Some of it's more towards thefield-ed stuff, but there's
still great information thereand our website is also full of
information, documents that youcan obtain from our bookstore,
the installation instructions,how to properly address water,
the checklist.
There is lots of freeinformation that you can
download and look at and there'saccess to articles on tanks.

(01:23:38):
It's hard to find tankinformation.
I mean I had to take salesmenout to lunch when I was first
learning this to try to.
They were the ones that knewthe stuff back in this was the
early nineties.
They were the ones that knewthings that and the installers
had to buy them beer.
But now it's being documentedand put together in some

(01:23:59):
specific places.
But yeah, our website's got alot of good information.
Certainly the PetroleumEquipment Institute, another
organization.
They write a lot of standards.
If you want to know thestandard for how to install an
above-ground tank for vehiclefueling, for marina, for backup
power, for bulk storage.
They have written those costyou money but they are kind of

(01:24:21):
the accepted standard for thingson how things get installed.
The fire codes have things.
Those aren't free but yeah, ifyou're looking for free, our
website's probably as good asyou're going to get.
But especially when you startto get into some specific
applications, you might have tolook for those construction
standards like the PEI ones aswell.
And then the manufacturers doit For the stuff attached to the

(01:24:45):
tanks.
Morrison Brothers has greatinformation, clay and Bailey has
great information.
They support their productswell.
A lot of the other ones thatmake stuff for tanks they will
support their products as well.

We use the Morrison Brother tank outlays,
with all the appurtenanceslabeled, to train our employees
when they start with us, becauseit's such a great layout.

Especially on small tanks.
When I would do a tank design,I'd start with that.
I got that.
I don't have that.
Yeah, that's the Morrison guys.
They do a great job ofsupporting the product.

They do Well.
Gentlemen, thank you so muchfor coming to Tank Talk today.
I really appreciated everythingyou had to share with us.
I have learned so much and ourlisteners, I am sure, are going
to enjoy this so much.
Is there anything you want tosay before we sign off, any last
words?

Don't hesitate to reach out with questions.
I am an industry resource forour members, but I also help
people who purchase our members'products.
Get them pointed.
We answer questions.
Let's put it that way.
So if you email us a question,we'll get you an answer.

Awesome, hi there.
This is Shannon Olkers and, asthe owner of Integrity
Environmental, I wanted to takea minute here at the end of the
podcast to make sure that youknew the following this podcast
is for informational purposesonly and should not be
considered legal or regulatoryadvice.
We are not responsible for anylosses, damages or liabilities

(01:26:08):
that may arise from the use ofthis podcast.
This podcast is not intended toreplace professional regulatory
or legal advice, and the viewsexpressed in this podcast may
not be those of the host thatwould be me or Integrity
Environmental.
Thank you very much forlistening and if you do need
professional regulatory advice,we'd be happy to help you as

(01:26:29):
part of our consulting services.

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