What to Look For in an Effective Inspection and Maintenance Program

The road to cost-effective environmental compliance is the implementation of a sound Inspection and Maintenance (I & M) Program.

Good engineering. . . sound investment
The road to cost-effective environmental compliance is the implementation of a sound Inspection and Maintenance (I&M) Program. Inspection and maintenance are necessary for both compliance and sound business practices. Owners and managers no longer ask whether or not they need I&M, but how much inspection and maintenence is needed.

Instituting an effective I&M Program, based on good engineering practices, can protect your financial resources because such a program is proactive, not reactive. The following areas should be considered when designing an I&M Program specific to your operations.

Figure 1 Environmental Site Assessment Areas Courtesy of Lexicon Environmental/Lennon Communications

Environmental site assessment
How do you know what’s going on at your facility or facilities? Chances are that many areas related to petroleum marketing are regulated. However, perhaps you haven’t kept up with the latest mandates or your company has downsized and, with increased responsibilities begging for your attention, you haven’t kept track of routine issues.

An environmental site assessment can help you identify areas requiring special attention. The site assessment forces you to look at every area of your operation, such as process equipment, storage tanks, wastewater discharges, monitoring systems and reporting requirements. Figure 1 provides a schematic of the areas to consider during an environmental site assessment. As you look at each area, ask yourself the following questions:

• Is this area of my operation regulated?
• Do I know the operative thresholds that change a non-regulated activity to a regulated one?
• Is this area of the operation well-maintained? Does it warrant frequent inspections and preventative maintenance?
• Can my staff implement the program? Will additional training be required? Is outsourcing an option?

Focus on the answers to these questions. By doing so, you can determine the type of I&M Program that will best benefit your operation. Once you’ve identified what is needed, objectively look at what steps can be implemented to keep your operation efficient and in compliance.

Process equipment
Every operation has a set of processes. For the most part, people rely on equipment (mechanical and/or electronic) to perform many of these processes, including meters, pumps, process vessels, controls, valving, piping and hydraulic lifts.

Routinely inspecting the critical parts of the process equipment (i.e., seals, gaskets, valves and joints) will save money in the long term. Because the equipment is routinely inspected, you will know about problems or potential problems that can be handled with minimal cost. By conducting a periodic inspection and keeping the equipment well adjusted and maintained, you will avoid a failure in equipment from seizing your operation or slowly “conveying” your resources to the environment.

Underground storage tanks
There has been much attention paid to underground storage tanks (USTs) in recent years and months. Mainly, the focus has been on the December 22, 1998 deadline imposed by the US Environmental Protection Agency (US EPA) regulations (40 CFR 280). Complying with these deadlines is an important first step. However, it’s not the end of the story.

Now that you have replaced or upgraded your USTs, you must be sure that the right controls are in place to prevent a release of product (i.e., release detection, spill prevention and overfill protection). To be effective, these controls must be maintained and operated on an ongoing basis. Under the federal regulations, some points to include as part of an I&M Program are:

• release detection systems must be operated and maintained according to the manufacturer’s instructions, including routine maintenance and service checks for proper operation.
• pressurized piping systems require an annual operational test of automatic line-leak detectors and annual tightness testing or monthly monitoring (e.g., interstitial monitoring, automatic in-tank gauging and vapor or ground water monitoring).

Figure 2 Examples of Monthly Monitoring Techniques Courtesy of EPA Office of Solid Waste and Emergency Response

Some monthly monitoring techniques are provided in Figure 2. The tightness test conducted must be accurate to 0.1 gallons per hour at 1H times the normal operating pressure.

• cathodic protection systems must be tested six months after installation, as well as every three years. Cathodic protection systems using impressed current must be inspected every 60 days.
• suction piping systems must be tested every three years if not equipped with monthly monitoring (unless the system has been designed according to certain criteria specified in the regulations).
• interior lined tanks must be inspected within ten years after installation and every five years thereafter.
• repaired tank systems must be tested 30 days after the repair if not monitored by one of the approved monthly monitoring methods.

The above information focused on the tasks that must be performed to keep USTs in compliance. But what about the routine steps you can take to be sure your systems operate properly? Routine inspection of manways, sumps and spill buckets can alert you to water infiltration problems that need to be addressed before the equipment is affected by standing water. Visible portions of the dispensing equipment, such as pumps, valves, fittings and piping, should be checked. Other points of inspection included here, and in Table 1, are:

• Alarms—Are the alarms in proper working order? Are the alarms visible and/or audible and placed in an area where action can be immediately implemented?
• API Color Coding—Is it appropriate for the product? Is it faded or worn?
• Labeling—Is the label missing? Does the label accurately reflect the contents?
• Signs—Are the appropriate signs in place to alert product delivery personnel about certain conditions (e.g., overfill alarms)? Are the signs legible?
• Spill Kits—Are they easily accessible? Do they need to be replenished? Do you need to order spill kits?

Aboveground storage tanks
Currently, aboveground storage tanks (ASTs) do not have federal regulations that are comparable to those for USTs. However, several comprehensive state programs (e.g., New York and Florida) and many industry codes/standards (e.g., API and NFPA) address the operation and maintenance of ASTs. And several federal regulations mandate compliance for various components of ASTs. Many states require the registration of ASTs.

ASTs have this advantage over USTs: You will be aware of a release sooner (assuming that you are paying attention); but you will still need a program of routine inspection and maintenance to avoid a catastrophic release.

A comprehensive visual inspection is an effective management tool to find early warning signs of a problem. In addition, a visual inspection is the easiest way to detect corroded or broken equipment. Other than corrosion, what are the critical points to consider?

• Foundations: Check concrete pads and AST support systems for cracks and evidence of stress (buckling). Check secondarily-contained ASTs for an accumulation of water and debris. Remove and properly dispose of this material as soon as possible. You should also note whether the water exhibits a sheen, which could indicate a minor spill or product release. Properly dispose of any materials in the containment area with a sheen and investigate the source of the release.
• Piping connections: The same type of foundation stress mentioned above can impact the piping as well. Look at the piping connections and supports frequently until the problem is corrected. Also inspect the pipe connections for external corrosion.
• Protective coatings: Evidence of rust, blisters and separation of the tank’s coating requires prompt attention. If left unattended, these areas could leak and corrode the primary shell. Separation of the tank’s coating near a seam could indicate a small leak.
• Tank walls: Inspect the tank walls for corrosion and signs of leakage. Evidence of cracks, change in shape, bulges and paint discoloration are all signs that problems are developing. Such signs require a thorough investigation of the source(s) of the problem.
• Pipes, valves, fittings and hoses: Conduct an inspection of the piping, valves and fittings. Check for leaks, misalignment, unstable piping supports, proper valve sealing, external corrosion and an accumulation of liquids.
• Instruments, control equipment and electrical systems: Maintain the equipment in operating condition at all times, per the manufacturer’s specifications.

It is a sound engineering practice to consider the additional points of inspection as outlined in the UST section (see Figures 1 and 2), such as alarms/monitors, API color coding, labeling, signs and spill kits. Figures 3 and 4 highlight areas that should be of concern during the inspection of ASTs.

Figure 3 Areas of concern in typical horizontal tank systems Courtesy of the Pennsylvania DEP Storage Tank Division.

 SPCC requirements
Does your tank storage require you to develop and implement a Spill Prevention Control and Countermeasure (SPCC) Plan? As outlined in 40 CFR 112, SPCC requirements also address periodic inspections and the correction of problems discovered. To determine if your operation is subject to the SPCC requirements, use the following as a guide if your facility could pose a threat to “navigable waters”* or adjoining shorelines in the event of a spill:

• total aboveground capacity is greater than 1,320 gallons; or
• a single AST has a capacity greater than 660 gallons; or
• total underground storage capacity is greater than 42,000 gallons.

Figure 4 Critical inspection areas of a ball valve Courtesy of Government Institutes.

* Navigable waters of the United States are defined in Section 502(7) of the Federal Water Pollution Control Act (FWPCA), and include: (1) All navigable waters of the United States, as defined in judicial decisions prior to passage of the 1972 Amendments to the FWPCA, and tributaries of such waters; (2) Interstate waters, including interstate wetlands; (3) Intrastate lakes, rivers, and streams which are utilized by interstate travelers for recreational or other purposes; and (4) Intrastate lakes, rivers, and streams from which fish or shell fish are taken and sold in interstate commerce.

API 653 considerations
Here is another consideration for AST owners: Is the storage subject to inspection in accordance with API Standard 653, Tank Inspection, Repair Alteration and Reconstruction. In many states, regulations mandate an API 653 inspection. API 653 also addresses inspection intervals. There are three types of inspections: routine in-service; formal in-service; and formal internal.

A certified API 653 inspector must perform the formal in-service and internal inspections. The routine inspection covers the same areas previously discussed that were related to AST inspections (foundations, piping connections, tank walls, instrumentation and control equipment). Under API 653, the formal in-service inspection must occur every five years and the formal internal inspection every ten to 20 years, depending on the condition of the tank.

Used oil
Under federal regulations, used oil is any refined crude or synthetic oil that, as a result of use, is contaminated by physical or chemical impurities. Used oil is presumed to be designated for recycling, and standards for its management are outlined in 40 CFR 279 of the Resource Conservation and Recovery Act (RCRA).

Are you managing your used oil properly? Following are the basic management standards for used oil:

• Storage—Store used oil in tanks, containers or other approved units. Storage units must be in good condition. Other applicable rules governing the storage of used oil include 40 CFR 112, SPCC requirements and, if storage occurs in USTs, 40 CFR 280.
• Labeling—Clearly identify containers, ASTs and fill pipes used to transfer used oil into USTs.
• Shipping—Use a transporter with an EPA identification number when shipping used oil off-site.
• Disposal—Track used oil disposal with a manifest or bill of lading. Also, be sure that the firm you use is reputable. Don’t be afraid to ask about past violations and penalties. Another disposal option, if allowed by local and state regulatory agencies, is to burn the used oil in on-site, used oil-fired heaters with a maximum capacity of 0.5 million BTUs per hour.
• Release response—The release must be stopped, contained, cleaned up and disposed of appropriately. The storage container must be repaired or replaced prior to being used again for storage.

As compared to the standards, how does your operation handle used oil? It is a good management practice to periodically check how used oil is handled to stay in compliance.

Monitoring systems
Under the federal UST regulations, release detection records must be kept current and maintained in accordance with the manufacturer’s instructions. Most monitoring equipment is equipped with a test button; push it on a routine basis to be sure it is working as specified by the manufacturer.

Some “high end” monitoring equipment has the ability to self-diagnose. Take advantage of these tools to assist you with your compliance efforts and include the inspection of the monitoring equipment as part of your I&M Program.

There are also services in the marketplace that can monitor your tank systems for regulatory compliance and product inventory information. This service can be provided through the use of “back-office” software for your company’s PC or through a centralized monitoring program. Such a service can usually be added to your current monitoring equipment by installing a modem and having access to a telephone line.

Wastewater discharges
Wastewater is generated through a variety of sources. It could result from sanitary sources, rainwater or water used as part of a manufacturing, heating or cooling process. No matter how wastewater is generated, you need to know where and how it is discharged.

Do you have oil/water separators? Have there been historical discharges to Class V injection wells? To where are your floor drains discharging ?

Check on whether or not the discharge is a permitted activity. If it is, do you have the required permit? Has it expired? Did something in the discharge process change where permitting is no longer required? If you don’t know the answers, use your local water and sewer authorities as a resource to find out the facts and learn how local rules and regulations may impact your operations.

Air quality
Air quality management is extremely complex and enters into many aspects of your operation. Many operations require permits and management plans. Air controls can be as simple as vented storage tanks and as major as establishing air pollution control and vapor recovery systems.

Recordkeeping
Once you’ve compiled all the information mentioned in this article, organize it. Keeping well-maintained records of your inspection activities shows you are on top of your operation’s compliance issues. Various regulations mandate inspections and recordkeeping requirements.

Figure out a way to keep your records together that works for you (files, notebooks, computer-generated databases) and use it.

We’ve covered a lot of ground, and the material may seem overwhelming. There is help available through written materials, the advice of environmental professionals or the outsourcing of I&M tasks. With fines running in excess of $11,000 per day per violation, instituting an I&M Program is an effective way to protect the financial resources of your operation.Reinforce what you have read by taking the pop quiz on the right hand page.

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