Alaska Department of Environmental Conservation

SPAR Chapter 75, Article 1, Aboveground Storage Tank Standards Update FAQs

Frequently asked questions (FAQs) from the public, expected or received, have been compiled along with the department’s responses. Substantially similar questions have been aggregated:

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Why does the department now allow for use of "similar service" to extend the initial internal inspection beyond 10 years?

Provisions within the proposed 5th edition of American Petroleum Institute’s (API) Tank Inspection, Repair, Alteration and Reconstruction (API 653) are prescriptive for similar service evaluations; whereas the 3rd edition was silent on the qualifying evaluation parameters for use of similar service

Why is the department removing the requirement for a P.E. signed quantitative risk-based inspection (RBI) assessment to be in accordance with API’s Risk Based Inspection (API 580)?

The 5th edition of API 653 incorporates the requirement that API 580 be used to support RBI assessments in support of an extension of the initial internal inspection beyond 10 years. All extensions of the 10-year initial internal inspection (historically used to establish corrosion rate) must also be submitted to and reviewed and approved by the department.

Why has the department removed the 30-year limitation for internal tank inspection intervals from regulation?

The 5th edition of API 653 limits the internal inspection interval to 20 years for tanks without a release prevention barrier or to 30 years (except as provided in Section 6.4.2.1.1).

Why does the department propose specific editions of the standards and not include any future amended versions?

Under AS 44.62.245, the department needs to be explicitly authorized by a statute to incorporate a future amended version of a document or other material. The department has not been authorized to do that in the Alaska Statutes.

What will happen to the Shop-fabricated Aboveground Oil Storage Tank Capacity Limit Guidance if the proposed amendments are implemented?

If the amendments are implemented, the guidance will be rescinded because it will no longer be applicable. This is due to updates to the referenced industry standards. The updated capacity is also reflected in the proposed language in 18 AAC 75.066(k).