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TEAM
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Do You Comply With the API-653 Inspection Frequency? A number of state regulatory agencies have adapted American Petroleum Institutes (API) standard 653 into their regulations. The state of Florida has not only incorporated API-653 by reference in Chapter 62-761.210(2)(b)10, but they have also identified adherence to specific portion of the standard, such as in the inspection frequencies. Most storage tank operators, especially those in the effected states, have been following the API-653 6.4 – Internal Inspection requirements for many years. They have set their baselines, determined the useful remaining life and have set their future in-service inspection intervals. They have all the out-of-service documentation necessary to satisfy the regulatory inspectors. Now the confusion
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. API-653 6.3.1 calls for routine in-service inspections. The owner/operator personnel can perform these inspections. These routine in-service inspections shall be done on a frequency not to exceed one month. And, as with all inspection, if it is not documented, it is not done! API-653 6.3.2 calls for external inspection. An
authorized API-653 inspector must perform these inspections. The frequency of
this external inspection is no longer than 5 years. The good news is that the
external inspection can be done while the tank is in service. And again, as with
all inspection, if it is not documented, it is not done! At the recent NISTM conference in Orlando,
Florida, there was a lot of discussion among the environmental regulators about
these in-service and external inspections. Some of the regulators have begun
asking the owner/operators for this documentation.
If the documentation does not exist, regulatory audit problems are soon
to follow. The regulators are becoming more knowledgeable about the requirements
outlined in API-653. As a result,
they are specifically asking for documentation that was never asked for
previously. Bottom Line: In-service inspections – monthly External inspections – every 5 years Internal inspection – not to exceed 20 years,
depending on corrosion rate. And, as always, Documentation!
If it's not documented, it's not done! |
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