**Docket ID No.EPA-HQ-OPA-2007-0584**

**Fiberglass Tank & Pipe Institute \~ December 4, 2007 Comments**

**Environmental Protection Agency**

**\[EPA-HQ-OPA-2007-0584; FRL-8479-7\]**

**RIN 2050-AG16**

**Oil Pollution Prevention; Spill Prevention, Control, and
Countermeasures Rule Requirements -- Amendments**

Following are comments submitted by the Fiberglass Tank & Pipe
Institute, 11150 S. Wilcrest Dr., Suite 101, Houston, Texas 77099-4343
Tel 281 568 4100 Fax 281 568 9998, Executive Director Sullivan D.
Curran, on the proposed subject rule published in the *Federal Register*
on October 15, 2007.

The Fiberglass Tank & Pipe Institute (Institute) appreciates the
opportunity to comment on the proposed changes to the Spill Prevention,
Control and Countermeasure (SPCC) regulations. The Institute was
incorporated in 1987 as a non-profit trade association, and it
represents the major manufacturers of underground and aboveground
fiberglass tanks and vessels in the United States. In addition to
aboveground stainless and lined steel tanks, fiberglass tanks and piping
are used to store and handle oily water, animal fats and vegetable oils
(AFVO). Thus, while not specifically mentioned in the Agency's 40 CFR
Part 112 proposal, such fiberglass tanks and piping are subject to the
proposed regulations. This being the case, the Agency needs to include
the fiberglass industry aboveground tank integrity standard FTPI 2007-1
*Recommended Practice for the In-service Inspections of Aboveground
Atmospheric Fiberglass Reinforced Plastic (FRP) Tanks and Vessels©*
(copy attached)*.*

Following are the Institute's comments, consistent with EPA's request
for additional information:

V.*J. Integrity Testing*

The Institute agrees that the owners or operators of all types of
facilities subject to either 112.8(c) (6) or 112.12(c)(6) should select
particular testing methods to comply with these requirements based on
industry inspection standards. EPA, therefore, [should
include]{.underline} FTPI 2007-1 for fiberglass above ground storage
tanks and vessels in either the rule itself or the preamble to the final
rule. The Steel Tank Institute's recommended practice (STI SP001) for
aboveground tank inspections does not cover fiberglass tanks and
vessels. Fiberglass tanks and vessels are a growing part of the
aboveground storage market.

A summary of FTPI 2007-1 is shown below and does not apply to portable
containers, but instead to tanks or vessels greater than 10,000 gallons.
Further, the summary describes that fiberglass inspector qualifications
limit certification to those who have experience with the inspection of
fiberglass tanks or vessels. Of significance, this excludes a
PE-certified explanation of environmental equivalence and deviation from
an industry standard.

V.*K. Animal Fats ad Vegetable Oils*

EPA's proposal essentially would forego integrity testing of bulk
storage containers subject to Food and Drug Administration (FDA)
regulation and which meet four other criteria by conducting visual
inspections will allow for the continuation of visual inspections of
tanks:

1.  evidence of material stress;

2.  when leaks are occurring;

3.  when there is a change of service to a dissimilar stored material;

4.  when a tank or vessel is relocated; and,

5.  by an untrained or certified person.

6.  

The Institute FTPI 2007-1 recommends a [certified]{.underline} external
tank and vessel inspector every 10 years for tanks/vessels greater than
10,000 gallons capacity when non-hazardous substances are stored. And,
annual inspections by a Preventive Maintenance inspector who was shown
to be familiar with the equipment and the FTPI 2007-1 content. The EPA
proposal is overly lax and should be reconsidered.

K.1. Differentiation Criteria

K.1.i *Container Foundations. FDA*

No comment other than FTPI 2007-1 includes an inspection of the tank or
vessel foundation.

K.1.ii *Container Support Structures. FDA*

No comment other than FTPI 2007-1 includes an inspection of the tank or
vessel support structures.

K.1.iii. *Container* *Itself*

*Internal Corrosion:* While the FDA requires the [initial]{.underline}
design, construction and use to preclude adulteration of food, there is
no assurance that it is "likely to prevent the corrosion of the internal
contact surface...." as stated. Thus, FTPI 2007-1 recommends an
integrity inspection after 20 years for tanks and vessels greater than
10,000 gallons capacity [or]{.underline} when other warning signs appear
as described above under K. This requirement is of more significance for
carbon steel tanks that are interior lined. Institute experience shows
that manufacturing defects, overheating or other processing problems
will over time reduce the integrity of tank and vessel interior such
that an integrity inspection is required.

*External Corrosion:* No comment other than FTPI 2007-1 includes a
monthly and annual visual inspection of the tank or vessel exterior.

K.1.c. *Containers Made from Austenitic Stainless Steel*

The Institute supports limiting consideration of alternative integrity
testing to only homogenous Austenitic stainless steel tanks and vessels
(see comment above regarding lined carbon steel tanks).

K.1.d. *Containers with No External Insulation*

The Institute supports limiting consideration of alternative integrity
testing no containers with no external insulation. Institute experience
is that external insulation is a barrier to effective visual examination
and is familiar with insulated tank ruptures occurring within a month of
an exterior inspection.

K.1.e. *Shop-Fabricated Containers*

The Institute does not support the rationale given for an alternative
integrity testing option for only shop-fabricated containers. While
field-erected tanks are larger than those of shop-fabricated tanks, they
are designed and constructed accordingly, meet long standing industry
standards and there are no data to support a higher failure rate.
Further, both the STI SP001 and the FTPI 2007-1 establish the frequency
for visual inspections that is applicable to field-erected tanks and
vessels. The Agency should not use this as a valid reason to limit
consideration of alternative integrity testing to only shop-fabricated
containers.

K.2. *Required Recordkeeping*

No comment other than FTPI 2007-1 includes monthly preventive
maintenance and integrity testing record keeping check lists that meet
SPCC Plan requirements.

K. 2. *Integrity Testing* for containers located indoors vs. outdoors

FTPI 2007-1, like API 653 and STI SP001, does not differentiate
inspection requirements for indoor versus outdoor containers. The
exterior roof and shell of fiberglass tanks and vessels are inherently
corrosion resistant, and whether they are located indoors or outdoors is
not a factor when visually or integrity inspected.

Following is background information on the Fiberglass Tank & Pipe
Institute and a summary of FTPI 2007-1 *Recommended Practice for the
In-service Inspections of Aboveground Atmospheric Fiberglass Reinforced
Plastic (FRP) Tanks and Vessels©:*

*Institute Purpose:* The Institute provides a forum through which the
fiberglass reinforced thermoset plastic (FRP) industry can work together
effectively toward the common goal of advancing the use of all
fiberglass products in the tank and piping marketplace, i. e.,
coordinating studies and statistics, combining talents and resources to
provide standard-setting organizations with superior technical data, and
disseminate information to the government, industry and the public.
Published information is available from the Institute web site at
[www.fiberglasstankandpipe.com](http://www.fiberglasstankandpipe.com/).

*Member company products:* Underground fiberglass tanks are located in
over 50% of the nations gasoline refueling facilities whereas
aboveground fiberglass tanks are used to store oily water, animal fats,
vegetable oils as well as industrial chemicals such as acids and
caustics. In addition, the Institute represents the major manufacturers
of small diameter fiberglass gasoline piping systems found underground
at most of the nations vehicle refueling facilities and large diameter
piping up to 155 inches in diameter for municipal potable and wastewater
applications.

FTPI 2007-1 *Recommended Practice for the In-service Inspections of
Aboveground Atmospheric Fiberglass Reinforced Plastic (FRP) Tanks and
Vessels©*

The Fiberglass Tank & Pipe Institute published FTPI 2007-1 in October
2007. This Recommended Practice was developed over the past three years
in response to requests by aboveground fiberglass tank users,
engineering companies and governmental bodies. Members of the Institute
and an industry peer review group have shared their fabrication,
operation and maintenance expertise on aboveground fiberglass tank in
corrosion resistant applications to make this publication possible.

*Peer review Group:* The Recommended Practice peer review group included
the Environmental Protection Agency; US Office of Emergency Management;
N. Y. State Dept. of Environmental Conservation Spill Response & Bulk
Storage Tank Section; Lyondell Chemical Inc.; two fiberglass Inspection
companies; three fiberglass Consultants and Engineering companies; and,
both Institute and non-Institute aboveground fiberglass tank
manufacturers.

*FTPI 2007-1:* The Recommended Practice is a 27 page document that
includes recommended inspector qualifications, periodic preventive
maintenance inspections, certified external inspections, certified
integrity inspections, internal inspections and alternate non-intrusive
inspection methods. The document also includes report forms for monthly,
annual and periodic preventive maintenance and certified inspections and
a section on aboveground fiberglass tank fabrication information.

#  The purpose of this Recommended Practice is to provide procedures for conducting periodic preventive maintenance (PM) inspections and certified inspections of fiberglass reinforced plastic (FRP) atmospheric tanks and vessels in corrosive industrial and commercial service after a set period of time and when there is a change of service. The procedures are intended to: 

-   minimize maintenance costs,

-   ensure compliance with environmental and safety requirements,

-   minimize system failures and

-   ensure that proper engineering, construction and maintenance
    practices are in place.

*PM Inspector Qualifications:* The Preventive Maintenance (PM) inspector
shall be a person familiar with the equipment to be inspected, this FTPI
2007-1 Recommended Practice, and is designated by the equipment owner or
operator. Periodic preventive maintenance tank and vessel inspections
are the process of ongoing data collection through exterior inspections
using investigative tools and methods. The inspection data should be
documented in a manner that provides for a long-term trend evaluation.

*PM Inspections:* Preventive Maintenance inspectors are required to
document tank or vessel inspections in written reports using where
applicable the minimum information included in FTPI 2007-1 standardized
check lists. In addition, the reports shall contain conclusions,
recommendations and supplemental sketches with dimensions and/or
photographs. The photographs shall have a minimum resolution of 3 mega
pixels with the photograph locations identified.

*Certified External and Internal Inspector Qualifications:* The
certified inspectors shall have education and experience equal to at
least one of the following:

a.  A degree in engineering plus one year of experience in the
    inspection of FRP tanks or vessels.

b.  A 2-year certificate in engineering or technology from a technical
    college, and two years of experience in manufacturing, repair,
    operation or inspection of FRP tanks or vessels manufactured in
    accordance with applicable standards or codes.

c.  The equivalent of a high school education, and three years of
    experience in manufacturing, repair, operation or inspection of FRP
    tanks or vessels manufactured in accordance with applicable
    standards or codes.

*Certified External Inspections:* Certified [external]{.underline} tank
and vessel inspections shall be performed by a certified tank or vessel
inspector as follows:

-   every 5 years for tanks or vessels in Hazardous Substance service,
    or

-   every 10 years for tanks/vessels greater than 10,000 gallons
    capacity and in other service, or

-   if evidence of material stress appears, or

-   tank or vessel leaks occur, or

-   before there is a change in service to a dissimilar stored material,
    or

-   if a tank or vessel is relocated.

*Certified Integrity* *Inspections:* Integrity tank and vessel
inspections shall be performed by a certified tank or vessel inspector
as follows:

-   every 20 years for tanks/vessels in Hazardous Substance service, or

-   every 20 years for tanks/vessels greater than 10,000 gallons
    capacity and in other service, or

-   if evidence of material stress appears, or

-   tank or vessel leaks occur, or

-   before there is a change in service to a dissimilar stored material.
    or

-   if a tank or vessel is relocated.

The report of Certified Inspections shall be delivered to the owner.
These reports shall include the inspector's recommendations, which shall
include one or more of the following:

1.  No remedial action

2.  Further investigation or analysis

3.  Repairs

4.  Changes in tank or vessel operation

5.  Replacement

**\* \* \* \* \***

The Institute appreciates this opportunity to present its views on the
proposed SPCC changes. Please feel free to contact us for additional
information as needed

Sincerely,

**Hardcopy signed and mailed to EPA Docket**

Sullivan D. Curran P. E.

CC: FTPI 2007-1 Recommended Practice

**Submitted in hardcopy format** **to Docket ID
No.EPA-HQ-OPA-2007-0584**