By now, most dealerships who qualify for SPCC plans have completed them, but how many of us are following up with the compliance of the SPCC regulations after the plan is in place?
Has your plan been signed by a dealership plan manager? Are the secondary containment descriptions accurate and in place? Is your dealership documenting monthly visual inspections? Are your tanks due for their 5 year SPCC review? Tank integrity testing was recently brought to my attention. Your dealership is responsible for complete tank integrity testing for all tanks onsite. This goes beyond the simple visual inspection. Here is the reg:
Federal (this requirement is not in effect until October 31, 2007) Under §112.108(c)(6), for bulk storage containers the owner must “Test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skid mounted, elevated, or partially buried). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing. You must …”
One of the testing methods described was a hydrostatic test such as the testing completed on fire extinguishers every 6 years. This testing will require assistance from a tank testing company.
