Is a tank inspection date enough?
A tank inspection date is not an integrity program.
A June 2026 proposal from the Pipeline and Hazardous Materials Safety Administration (PHMSA) is renewing attention on how tank-inspection intervals are established.
The proposal would update the edition of API Standard 653 incorporated into PHMSA’s hazardous-liquid pipeline regulations and allow risk-based inspection procedures to help establish internal inspection intervals for regulated pipeline breakout tanks. It is not yet final, and it applies to a specific category of tanks—not every AST, UST, or facility fuel tank.
Still, the proposal highlights a broader tank-integrity issue: an inspection due date alone does not demonstrate that a tank is being actively managed.
A defensible inspection interval should consider:
- Previous inspection findings, repairs, and unresolved deficiencies
- Corrosion rates, thickness data, floor condition, coatings, and settlement
- Product service, operating changes, and known degradation mechanisms
- The potential environmental, safety, and operational consequences of a release
- Requirements under the applicable standard, regulation, SPCC Plan, or state program
Risk-based inspection does not mean less inspection. It means the basis for an inspection interval must be documented, technically supported, and reevaluated when conditions change.
For tank owners and facility managers, the question is not only, “When is the next inspection due?” It is also, “Do we have the records and condition data to support why that interval is appropriate?”
Read the proposed rule: PHMSA Pipeline Safety: Breakout Tank Inspection Rule.
For questions or to request a proposal contact: Carol LaRosa, Inspection Business Administrator, at caroll@ttienv.com or John Trotto, Director of Inspections, at johnt@ttienv.com
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