EPA Lauded For Proposed Rule On In-Service Tank Inspections

Kathryn Clay, president of the International Liquid Terminals Association, which has many members that operate liquids terminals on the inland waterways, commended the U.S. Environmental Protection Agency October 7 for proposing a rule to allow added flexibility to terminal operators while maintaining scheduled tank inspection timelines.

The new rule will allow more inspections that don’t require taking the tanks out of service.

“The new rule will broaden the applicability of a more modern standard that has applied for years to above-ground storage tanks subject to Maximum Achievable Control Technology requirements,” Clay said. “Under appropriate circumstances, this update will allow industry to maintain compliance commitments without unnecessarily taking tanks out of service.

“The EPA rule announced [October 7] is a common-sense solution that will lower emissions, ensure safety and provide operators with increased regulatory flexibility. By allowing greater use of a well-established, safe and effective inspection method, this new policy is a meaningful contribution to our shared goal of environmentally responsible facility management,” she said.

Two Compliance Pathways
Clay explained to The Waterways Journal that the rule allows two compliance pathways for terminal operators to inspect tanks. The coronavirus crisis complicated tank inspection schedules. Demand slowed immediately and dramatically as lockdown provisions took hold and driving fell, while oil production took a while to adjust. In the early days of the virus, storage facilities were full to capacity and overwhelmed, and it was impossible to take tanks out of service for required inspections during the summer.

Clay stressed that the new accommodation is not a “weakening” of inspection rules. At one time, all tanks were taken out of service every 10 years for inspection as an industry best practice. But as tank construction, materials and seals improved, that was no longer automatically necessary in all cases, she said.

In addition, it was found that the process of taking tanks out of service for inspection itself caused extra emissions, so allowing in-service inspections of tanks actually reduces emissions, Clay said.