Marine Transfer Operations, Hosing, Pipelines, Connections and Joints

Transfer operations are covered in 40 CFR 112.7 (e)(3).  This regulation covers piping, valves, gauges, regulators, compressors, pumps and other mechanical devices used to transfer oil from one area to another within a facility. Pipelines used to transport oil for interstate or intrastate commerce are considered transportation-related systems and are regulated under the DOT OPS program. Pipelines which are used for the transport of oil exclusively within the confines of a non-transportation-related facility are regulated under the SPCC program. Some of the more common mechanical transfer systems are the piping systems required to transfer product between tanks and railcar or truck loading and unloading areas.

Underground piping must have a protective wrapping and coating, and cathodically protected if used in corrosive soil conditions. If any section of buried piping is exposed for any reason, it must be examined for deterioration and corrosion and repaired, if necessary. Obviously, buried piping cannot be visually examined and must be subjected to periodic pressure testing, regardless of materials of construction. Plastic or fiberglass-reinforced pipes do not require protective coatings or cathodic protection.

Inspections

Tanks, pipes, joints, gaskets and seams should be inspected routinely for for visible oil leaks.  The inspection should be recorded on an inspection form and kept for three years.  Typically tanks and transfer operations are inspected once a week.  All visible leaks should be reported to the person in charge of spill prevention as noted in the SPCC Plan.  Inspections reports should be kept for three years.

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