EPA Clarifications for AST Owners

The July, 2002 SPCC update issued by the EPA created several concerns for Shop Fabricated AST owners.  These included integrity testing, loading rack containment, bulk plant security and the definition of impracticality. Of these concerns, the main two that concern ConVault aboveground storage tanks (AST) owners are: 

1. The requirement for integrity testing on a regular basis in section 112.8(c)(6); and
2. The interpretation of section 112.7(h). This section appeared to require containment systems for the delivery truck that brings fuel to the AST. 

Both of these concerns were addressed in the March 31, 2004 meeting with the EPA discussed the PMAA/EPA settlement agreement. 

Conclusions:

1. EPA will allow a visual inspection to qualify as an "equivalent environmental inspection" as long as :

a. The shop-fabricated AST is 30,000 gallons or less,

b. Is elevated in a manner that decreases corrosion (as compared to a container in contact with soil), and

c. All sides of the container, including the bottom, are visible during inspection.

EPA intends to develop guidance in the near future on appropriate visual inspection of shop-built containers. ConVault has prepared a memo starting that ConVault does not recommend integrity testing. The PE can use this memo in his documentation when preparing the SPCC plan. 

2. EPA has confirmed that the loading and unloading area containment requirement only apply to facilities with loading racks such as fuel jobber yards, not to AST's at other locations. 

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