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Issue link: https://read.dmtmag.com/i/108236
MARKETING & SUPPLY by KeithReID Is anything exciting happening on the regulatory front for aboveground storage tank operators? BUlK PlanTS In RegUlaTORY fOCUS T nPn FoCuses primariLy on the regulatory and legislative challenges the industry faces today and will likely face in the near future. Fortunately, to start off on a good note there is one area of industry operations—AST bulk storage plants—where there's not a great deal new to report. NPN interviewed Ed Sapp, president of UNI Engineering, Inc. headquartered in Hightstown New Jersey, for his insight. UNI is a provider of industrial, commercial, and governmental engineering and design services. Founded in 1977, its clients range from small independent architects to large multi-national oil and chemical firms in areas that include bulk liquid storage and trans-shipment facilities. his issue oF Sapp: We've been going to seminars and conferences for years and every year they are still writing the regs—there is always an addendum or "leave this paragraph blank to be filled in." They have finalized it in (most) major areas including using the Steel Tank Institute STI SP001 Standard for the Inspection of Aboveground Storage Tanks. NPN: Are there some areas you have to look at that might be covered from a regulatory standpoint but that don't necessarily receive the priority they deserve in the field? Sapp: One of the things that we do as part of our inspection is look at the secondary emergency containment. We will look at such things as the structural integrity, drainage, NPN: There's quite a bit of regulation impacting down- signage for locating drain valves and things like that a lot that stream petroleum in the marketer and retailer sectors. Is gets overlooked and we try to point that out to our customers. there anything happening at the federal level relative to That should all have been covered in the SPCC plan but that is aboveground bulk storage tanks? not always the case and that you have things like permeability requirements which can vary from state to state as well as volSapp: Traditionally each state has its own requirements and ume requirements. we don't know of anything federally in the works. We're not aware of the EPA putting out anything formally and typically NPN: With state budgets being what they are today, what is most states follow a five-year in-service inspection schedule and a the inspection and enforcement environment like? 10- or 20-year out-of-service schedule. They basically follow API 653. As far as the five-year in-service is concerned it involves such Sapp: That varies. For example, in Pennsylvania the things as a visual inspection, of course, UT (ultrasonic thickness) owners have to pay a yearly registration fee for the tanks. reading and elevation/settlement survey as part of a general That program generates money so they have people who checklist. With the out-of-service inspection you actually go into can go out and have surprise visits or scheduled visits to the tanks after they've been cleaned and certified gas free. make sure everybody is in compliance. The rest of the states… you do not hear too many complaints about reguNPN: You mentioned the most states are basically plugging lators coming out. Of course I would say 99 percent of the along, has there been anything particularly exotic pushed in people we work with are above board and in compliance any of the states recently? or are simply accidentally out of compliance because of some oversight. Sapp: No, actually it's been pretty much status quo. NPN: What are some legal ramifications for not being in NPN: One recent federal requirement has been the Spill compliance? Prevention, Control, and Countermeasure (SPCC) rule that covered preparing a plan to address potential waterway Sapp: You could be fined on a daily basis and in a worstcontamination and antiterrorist threats. The compliance case scenario have your operation shut down until they deadline was 2010, so how has that settled out? remediate the problem. 12 JaNuary/February 2013 NPN Magazine n www.npnweb.com