ILTA, working with AFPM and API, continues to seek a solution to the problem of upcoming out-of-service tank inspections, despite at- or near-capacity storage because of sluggish COVID-19 fuel demand. We, and the other groups, are working to have EPA allow in-service (keeping the product in the tank) inspections of tanks in lieu of emptying, cleaning and inspecting them. The agency has informed us that it plans to issue a rule that would allow this alternative type of inspection and would finalize it by the end of the year. It also plans to issue an interim policy that would allow tank operators to conduct in-service inspections until the rule is finalized.
During the COVID-19 pandemic, there has been a drastic reduction in demand for all sorts of products stored in aboveground tanks. This has made certain inspections that can require emptying a tank harder or even impossible to conduct, because with lower demand, storage space is at a very high rate of utilization. There is very little excess capacity into which to empty the contents of a tank to be inspected. Tanks with internal floating roofs that are regulated under 40 CFR Part 60 Subpart Kb are impacted by this situation.