Saturday, June 18, 2016
Shawn Zablocki, Program Leader
Certain government regulations require integrity inspections of ethanol tanks, vessels, and process piping. In particular, the Occupational Safety and Health Administration’s (OSHA) Process Safety Management (PSM) Rule and the Environmental Protection Agency’s (EPA) Risk Management Program (RMP) and Spill Prevention, Control and Countermeasure (SPCC) regulations require that this testing be performed. While EPA and OSHA require that testing and inspection be performed, they do not dictate how to perform these tests. This leaves the affected facilities to determine the applicable codes and standards to inspect their equipment against.
Many ethanol facilities are unsure of the actual requirements for integrity testing of their tanks, vessels, and pipes. This can mean additional cost caused by performing testing that may not be required, performing inspections more frequently than required, or worse, not performing inspections at all.
I presented this topic at the Midwest Environmental Compliance Conference in Overland Park, Kansas, and more recently, at the Fuel Ethanol Workshop in Milwaukee. The purpose of this presentation was to educate the audience on inspection requirements. I discussed the OSHA and EPA regulations that require integrity testing of tanks, vessels, and pipes; the applicable codes and requirements for testing; acceptable approaches to developing a compliant mechanical integrity inspection program; and some common issues seen in actual inspections of ethanol facilities. The discussion focused on industry best practices in developing a mechanical integrity program and ensuring proper documentation of the maintenance activities performed. I taught the audience the differences between American Petroleum Institute (API) standards and Steel Tank Institute (STI) standards and which tanks and vessels each code should be applied to.
The discussion also delved into the mandatory requirements of the codes and standards, options on how facilities inspect their equipment, and the recommended approach from certified API and STI inspectors. The intent was to provide the audience with the baseline information needed to tailor a mechanical integrity program to suit their facility’s needs.
If you would like to hear more about my presentation, please contact me at 402.938.2414.