Terminal operators are required to conduct out-of-service inspections on certain tanks every 10 years, but the current, unprecedented demand for storage has meant that operators have been unable to empty tanks to conduct them. ILTA brought this situation to the attention of EPA in Mid-April and, working with API and AFPM, has been seeking a solution that would allow in-service inspections of those tanks as an alternative.
EPA indicated in late June that it plans to extend its COVID-19 Enforcement Policy for certain operations impacted by the pandemic, including out-of-service tank inspections, through the end of September. The agency also plans to propose a rule in August to allow in-service inspections of these tanks and finalize that rule by the end of the year. It is considering how it might bridge the gap between the end of September and when the final rule goes into effect.
This is an extremely positive outcome as it avoids making terminal operators take extreme measures to empty and conduct out-of-service tank inspections when product demand remains low and tank utilization rates remain high.