AUGUST 2021

Jurisdictional Regulations
for Tank Risk-Based Inspection
USA Refineries, Chemical Plants, & Terminals

Applicable to Tanks Not Regulated by 49 CFR Part 195

20600 Chagrin Blvd., Suite 1200 SATE L L I T E O F F I C E C O N TAC T EMAIL WE B S IT E

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Tank RBI Overview
In recent editions of API STD 653, Tank Inspection, Repair, Alteration, and Reconstruction, the use of
Risk-Based Inspection (RBI) has been permitted as a means of determining the next inspection date
for initial and subsequent internal inspection of storage tanks. In accordance with API 653, the RBI
assessment must consist of a systematic evaluation of risk, which is the product of the likelihood,
or probability of failure (POF), and the associated consequence of failure (COF) in accordance with
API RP 580, Risk-Based Inspection.

Tank RBI has often been used by owner-users as a means of evaluating a deferral of an internal inspection
that was scheduled based on a prescriptive (or time-based) interval, when RBI was permitted to be used in
this manner by the jurisdiction. However, tank RBI has other uses, such as determining and optimizing
inspection activities for all tanks in a terminal or facility’s tank farm.

A S M A R T E R W AY T O I N S P E C T

Align inspection strategy Develop a repeatable risk Proactively evaluate how Reduce the risk
with risk & projected assessment across the change of service will image of an unexpected
financial impact entire organization inspection schedules failure

Some jurisdictions use different editions of API STD 653. This document is an outline of current regulations,
NOTE:
by jurisdiction, for tanks not regulated by 49 Code of Federal Regulations (CFR) Part 195 Transportation of
Hazardous Liquids by Pipeline at US-based refineries, chemical plants, and terminals.

This guide is current as of July 2021; however, to maintain compliance with the latest jurisdictional regulations,
please check with the relevant State or Federal regulator for any changes or updates before proceeding with
a tank RBI program.

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

2 Jurisdictional Regulations for Tank Risk-Based Inspection
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 Alabama Montana
USA Jurisdictional Regulation for Tank RBI
Alaska Nebraska
Click the state to access additional information on jurisdictional requirements for storage tanks not regulated by 49 CFR Part 195.
Arizona Nevada

Arkansas New Hampshire

California New Jersey

WA
Colorado New Mexico ME
New York
MT ND
Connecticut
VT
Delaware North Carolina OR MN
NH
District of Columbia North Dakota ID WI NY MA
SD
MI RI
Florida Ohio WY
CT
Georgia Oklahoma PA NJ
IA
NE DE
Hawaii Oregon NV OH
IL IN MD
Idaho Pennsylvania UT
WV DC
CO
CA VA
Illinois Rhode Island KS MO
KY
Indiana South Carolina
NC
Iowa South Dakota TN
AZ OK
Kansas Tennessee NM AR SC

Kentucky Texas
MS AL GA
Louisiana Utah

TX LA
Maine Vermont

Maryland Virginia AK
FL
Massachusetts Washington

Michigan West Virginia

HI
Minnesota Wisconsin

Mississippi Wyoming
LEGEND
Missouri
Jurisdictions that DO allow Tank RBI Jurisdictions that DO NOT allow Tank RBI

E²G considers states with no regulations accepting of RBI assessments

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

3 Jurisdictional Regulations for Tank Risk-Based Inspection
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State Allows Tank RBI Relevant Section of Code E²G Comments

Alabama No specific state regulations No information available

Alaska Yes 18 AAC 75.065. Field-constructed aboveground oil storage tank requirements Section (3) (A) RBI is permitted, as long as it is submitted to DEC
READ MORE
“A quantitative risk assessment, signed by a registered engineer and conducted in accordance with the API’s with inspection interval
Risk Based Inspection, First Edition, May 2002 (API RP 580), adopted by reference” E²G has conducted tank RBI assessments in Alaska

Arizona No specific state regulations No information available

Arkansas No 2206.2.3 Above-ground tanks located outside, above grade

READ MORE
“Above-ground tanks used for outside, above-grade storage of Class 1 liquids shall be designed, constructed,
and maintained in accordance with one or more of the following nationally recognized enginering standards
and be in accordance with Chapter 34. Such tanks shall be located in accordance with Table 2206.2.3.”

California No 5.6 What industry standards may be used for the integrity testing requirements of 40 CFR Section 112.8( c)(6)
READ MORE
“The two main industry standards for aboveground steel tanks storing flammable and combustible liquids
include the Steel Tank Institute (STI) SP001 Standard for the Inspection of Aboveground Storage Tanks and
American Petroleum Institute (API) Standards 653, Inspection, Repair, Alteration, and Reconstruction....
... For more information on inspections, evaluations, and integrity testing requirements under the SPCC rule,
refer to Chapter 7 of the SPCC Guidance for Regional Inspectors.”

Colorado Yes 3-3-4-2 Inspections Used 2019 PDF version

READ MORE
“All steel ASTs shall be inspected and maintained in accordance with STI SP001, “Standard for the Inspection
of Aboveground Storage Tanks”, or API Standard 653, “Tank Inspection, Repair, Alteration, and Reconstruction”,
whichever is applicable.”

Connecticut No specific state regulations No information available

Delaware Yes 6.0 Inspection Requirements for Metallic Field-constructed ASTS

READ MORE
“6.4.6 Alternative internal inspection intervals may be established as outlined in API 653 using the risk based
inspection procedures, robotics, statistical analysis, and related methods allowed by API 653, only for ASTs
with 110% secondary containment dikes and a continuous method of leak detection. Any alternative method
shall be approved in writing by the Department prior to implementation.”

District of Columbia Yes No specific state regulations

Florida Yes (6) Evaluation and testing. Shop fabricated - no

READ MORE
“Tanks shall be evaluated and the re-testing frequency established and implemented in accordance with API Field erected - yes
Std 653, November 2014, incorporated by reference in subsection 62-762.411(3), F.A.C. Storage tanks shall
be evaluated at the time of installation. Evaluations shall be certified by a professional engineer licensed
in the State of Florida, or approved by an API Std 653 certified inspector. Non-destructive testing shall be
performed by qualified personnel as specified in API Std 650, March 2013, incorporated by reference in
subsection 62-762.201(67), F.A.C., and API Std 653, November 2014.”

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

4 Jurisdictional Regulations for Tank Risk-Based Inspection ** E²G assumes states that do not provide specific regulations allow tank RBI
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State Allows Tank RBI Relevant Section of Code E²G Comments

Georgia No specific state regulations No information available

Hawaii No specific state regulations No information available

Idaho No specific state regulations 5706.7 Refineries

READ MORE
“Plants and portions of plants in which flammable liquids are produced on a scale from crude petroleum,
natural gasoline, or other hydrocarbon sources shall be in accordance with Sections 5706.7.1 through
5706.7.3. Petroleum-processing plants and facilities or portions of plants or facilities in which flammable or
combustible liquids are handled, treated, or produced on a commercial scale from crude petroleum, natural
gasoline, or other hydrocarbon sources shall also be in accordance with API 651, API 635, API 752, API 1615,
API 2001, API 2003, API 2009, API 2015, API 2023, API 2201, and API 2350.”

Illinois No specific state regulations No information available E²G has conducted tank RBI assessments in Illinois

Indiana No specific state regulations No information available

Iowa No specific state regulations No information available Only mentions chapters as the inspection code, not
READ MORE
API 653

Kansas No specific state regulations No information available

READ MORE

Kentucky No specific state regulations No information available E²G has conducted tank RBI assessments in Kentucky

Louisiana No specific state regulations No information available No specific code called out
READ MORE
E²G has conducted tank RBI assessments in Louisiana

Maine Yes AST Inspection & Monitoring (Page 11)

READ MORE
“Generally, tanks are required to be tested for integrity on a regular schedule. The inspection must be
conducted by a certified inspector, and include both visual inspection and one or more means of
non-destructive examination... An inspection frequency of every ten years is widely used for shop fabricated
aboveground storage tanks. The use of an industry standard procedure such as STI - SP-001 or API 653 is
strongly recommended...”

Maryland No specific state regulations No information available

READ MORE

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

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State Allows Tank RBI Relevant Section of Code E²G Comments

Massachusetts Yes 5.05: Self-inspection and Use Permit Requirements A verified inspector has to come and API 653
READ MORE
“(1) General. Pursuant to M.G.L. c. 148, 37 and as a condition to maintaining or renewing the use permit inspectors are qualified
issued by the Marshal, every aboveground storage tank subject to the requirements of 502 CMR 5.00 shall
be inspected in accordance with an Approved Standard by a Qualified Tank Inspector...”

Michigan No specific state regulations No information available No specific code called out other than NFPA 30
READ MORE
E²G has conducted tank RBI assessments in Michigan

Minnesota Yes Subp. 6. Tank Inspection Initial inspection shall be 10 years

READ MORE
“All field-erected steel tanks must be internally and externally inspected by a certified tank inspector E²G has conducted tank RBI assessments in Minnesota
pursuant to American Petroleum Institute Standard 653. Initial inspections must be completed in accordance
with the following schedule: A. external inspections shall be conducted by November 2, 2003, or a
maximum of five years after the initial construction date, whichever is later; and B. internal inspections
shall be conducted by November 2, 2008, or a maximum of ten years after the initial construction date,
whichever is later.”

Mississippi Yes Aboveground Storage Tanks “All aboveground tanks are regulated by the EPA”
READ MORE
“In Mississippi, all aboveground tanks are regulated by the Environmental Protection Agency (EPA). and in the EPA, tanks are inspected according to
EPA’s Aboveground Storage Tank Program is administrated by the Region 4’s Emergency Response API 653; however, check with local fire marshal and
Program.... For aboveground tanks, also check with the local Fire Marshal’s office and city and county city or county governments
governments for any regulations that they might have regarding aboveground storage tanks. Aboveground
propane tanks are regulated by the L C Gas Division of the Insurance Department.”

Missouri No specific state regulations No information available No specific code called out other than NFPA 30
READ MORE

Montana No specific state regulations No information available No specific code called out other than NFPA 30
READ MORE

Nebraska No specific state regulations No information available

Nevada No specific state regulations No information available Initial Enrollment

READ MORE
“With the exception of Marina ASTs, AST systems in
Nevada are not federally or state regulated…”

New Hampshire No Env-Or 306.09 Interior Inspections of ASTs. Schedule is defined, but inspection contents per 653
READ MORE
“(c) Detailed inspections of tank interiors as described in (d), below, shall be performed in accordance
with the following schedule:
(1) For tanks where any part of the shell is in contact with the ground, the initial inspection for previously
uninspected tank systems shall be performed when the tank is 10 years old.
(2) For tanks where the tank shell is entirely off the ground, such as tanks on racks or in cradles, the initial
inspection for previously uninspected tank systems shall be performed when the tank is 20 years old.
(3) Following the initial inspection, an inspection shall be performed at least every 5 years for tank systems
containing gasoline, and at least once every 10 calendar years of the in-service life of the tank for tank
systems containing other motor fuels, heating oils, and fuel oils.”

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

6 Jurisdictional Regulations for Tank Risk-Based Inspection ** E²G assumes states that do not provide specific regulations allow tank RBI
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State Allows Tank RBI Relevant Section of Code E²G Comments

New Jersey No Subsequent Testing (pg.3) Specifically disallows similar service and RBI
READ MORE
“Subsequent testing must be performed as specified under N.J.A.C. 7:1E-2.16(d) through (i); the testing to
be performed depends on the material of construction of the tank and whether the tank is shop-built or
field-erected.”

New Mexico Yes 20.5.110.1001 Operations and Maintenance Plan New tank regulations took effect on July 24, 2021
READ MORE
“B. Owners and operators shall use one or more of the following to comply with the requirements of
this section:
(1) American Petroleum Institute 570, “Piping Inspection Code: In-Service Inspection, Repair, and Alteration
Piping Systems”
(2) American Petroleum Institute Standard 653, “Tank Inspection, Repair, Alteration, and Reconstruction”
(3) Steel Tank Institute Standard SP001, “Standard for Inspection of In-Service Shop Fabricated Aboveground
Tanks for Storage of Combustible and Flammable Liquids”

New York No (b) Inspections of AST systems. Specifically disallows similar service and RBI
READ MORE
“Inspections of AST systems must be conducted in accordance with the following:
(1) Monthly inspections. The inspection must include, as applicable, identification of leaks, cracks, areas of
wear, corrosion and thinning, poor maintenance and operating practices, excessive settlement of structures,
separation or swelling of tank insulation, malfunctioning equipment, and structural and foundation
weaknesses. [...]
(2) Ten-year inspections. The inspection must include:
(i) an inspection that is conducted in accordance with API Standard 653 (April 2009) or STI SP001
(September 2011), and a tightness test of any underground piping; or
(ii) a tightness test of the AST system that is performed in accordance with subdivision (c) of this section.”

North Carolina No specific state regulations No information available

READ MORE

North Dakota No specific state regulations No information available

Ohio Yes (7) 5706.7 Refineries E²G has conducted tank RBI assessments in Ohio
READ MORE
“Plants and portions of plants in which flammable liquids are produced on a scale from crude petroleum,
natural gasoline or other hydrocarbon sources shall be in accordance with paragraphs (F)(7)(a)(5706.7.1) to
(F)(7)(c)(5706.7.3) of this rule. Petroleum-processing plants and facilities or portions of plants or facilities in
which flammable or combustible liquids are handled, treated, or produced on a commercial scale from crude
petroleum, natural gasoline, or other hydrocarbon sources shall also be in accordance with API 651, API 653,
API 752, API 1615, API 2001, API 2003, API 2009, API 2015, API 2023, API 2201, and API 2350 as listed in
rule 1301:7-7-80 of the Administrative Code.”

Oklahoma No specific state regulations No information available

Oregon No specific state regulations No information available

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

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State Allows Tank RBI Relevant Section of Code E²G Comments

Pennsylvania No § 245.553. Out-of-service inspections. API 653 calculated service life or half-life, with 20
READ MORE
“(e) Inspection intervals for out-of-service inspections are as follows: year maximum for out of service inspections and five
(1) Aboveground storage tanks shall be initially inspected based on measured corrosion rates. When the years for in-service inspections
corrosion rate is unknown, such as with new tank bottoms, the tank’s actual bottom thickness shall be E²G has conducted tank RBI assessments in
determined by inspection within 10 years of installation to determine the corrosion rate. Pennsylvania
(2) Aboveground storage tanks shall have an out-of-service inspection at their API 653 calculated service life
or 1/2 of the corrosion rate life, with a maximum of 20 years from the last out-of-service inspection.”

Rhode Island No 2.10.D Facilities Inspection RBI not specifially allowed, but 10-year inspection
READ MORE
“2. Ten-year inspections; exemption allowed for 650 tanks
b. Exemptions; Ten-year inspections are not required for the following unless otherwise specified: […] (3)
Tanks installed in conformance with standards for new construction as set forth in §§ 2.10(I)(1) through (7)
of this Part.”

South Carolina Yes Aboveground Petroleum Storage Tanks References EPA, which allows RBI through reference
READ MORE
“Although the S.C. Department of Health and Environmental Control (DHEC) does not regulate aboveground to API 653
storage tank (AST) systems, this information is provided for AST system owners to minimize any adverse
impacts they may have on the environment and prevent potential petroleum releases. This information,
however, does not replace any existing applicable laws or regulations. Guidelines and requirements from
the U.S. Environmental Protection Agency (EPA) and other nationally recognized publications also are
available at https://www.epa.gov/ust/aboveground-storage-tanks. Federal Spill Prevention Control and
Countermeasures (SPCC) requirements must be followed as appropriate.”

South Dakota No 74:56:03:05 Internal inspection requirements For over 250,000 gallon (946,000 liter) facility two
READ MORE
“(1) All owners or operators of AST systems which are located at a facility of a total capacity of 250,000 years then 10 years
gallons or less must internally inspect their tanks every two years until they comply with one of the
requirements in subdivision 74:56:03:04(1);
(2) All owners or operators of AST systems which are located at a facility of a total capacity over 250,000
gallons must internally inspect their tanks located at that facility every two years until they comply with
subdivision 74:56:03:04(3);
(3) After meeting the requirements in subdivision 74:56:03:04(1), all owners or operators of a facility of
250,000 gallons total capacity or less must internally inspect their tanks every ten years. Those AST systems
which have only release detection must be internally inspected every five years;
(4) After meeting the requirements in subdivision 74:56:03:04(3), all owners or operators of a facility over
250,000 gallons total capacity must internally inspect their tanks every ten years.”

Tennessee No specific state regulations No information available

Texas No specific state regulations No information available E²G has conducted tank RBI assessments in Texas

Utah No specific state regulations No information available

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

7 Jurisdictional Regulations for Tank Risk-Based Inspection ** E²G assumes states that do not provide specific regulations allow tank RBI
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State Allows Tank RBI Relevant Section of Code E²G Comments

Vermont No § 9-306 Inspection of Tank Systems. E²G has conducted tank RBI assessments in Vermont
READ MORE
“(b) Frequency of inspections. A tank system shall be inspected at the following times, where applicable:
(1) Immediately after tank system installation;
(2) Immediately after initial delivery of fuel to the tank system;
(3) Prior to the initial delivery of fuel to the tank system when the tank owner switches fuel carriers;
(4) If not otherwise required under subdivisions (1), (2), or (3) of this subsection, the tank system shall be
inspected once every three years; and
(5) Upon removal of a tank system under § 9-307 of these rules.”

Virginia Yes Part III. Pollution Prevention Requirements Company has to provide documentation to the board
READ MORE
“9VAC25-25-91-130. Pollution prevention standards and procedures. to extend past 10 years
5. Visual daily inspection and weekly inspections.
d. The operator shall promptly remedy unsatisfactory facility and equipment conditions observed in the
daily and weekly inspections. The operator shall make repairs, alterations, and retrofits in accordance with
American Petroleum Institute (API) Standard 653, Fourth Edition (April 2009), with Addendum 1 (August 2010)
and Addendum 2 (January 2012), Steel Tank Institute (STI) standard STI-SP001, Fifth Edition (September
2011), industry standards, or methods approved by the board.”

Washington No specific state regulations No information available

West Virginia Yes §22-30-5. Aboveground Storage Tank Regulatory Program Company has to inform secretary of how they adhere
READ MORE
(a) The secretary shall develop a regulatory program for new and existing regulated aboveground storage to API 653
tanks and secondary containment that takes into account the size, location, and contents of the tanks and
sets out tiered requirements for regulated tanks. Level 1 tanks shall be regulated to a higher standard of tank
and secondary containment integrity based upon their proximity to a public surface water supply source or
public surface water influenced groundwater supply source. [...]”

Wisconsin Yes (8) Maintenance and repairs

READ MORE
“(8) (a) 2. Field-erected aboveground storage tanks shall be maintained and repaired in accordance with API
653.”

Wyoming Yes Section 36. AST Leak Detection Requirements Annual inspections still required, but no comment on
READ MORE
“(b) ASTs With a Capacity of 100,000 Gallons or Larger. Owners and/or operators of ASTs with a capacity schedule for full internal inspections
of 100,000 gallons or more shall follow the inspection requirements of API Standard 653, as referenced in
Section 2.”

ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.

8 Jurisdictional Regulations for Tank Risk-Based Inspection ** E²G assumes states that do not provide specific regulations allow tank RBI
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Tank RBI Overview
A Smarter Way to Inspect
It’s costly and time consuming to inspect storage tanks. To optimize
costs and inspection schedules, RBI can replace the traditional API
653, time-based, inspection intervals for initial and all subsequent
inspections of storage tanks.
E²G offers a quantitative RBI methodology based upon API 581 to help
organizations and tank farm or terminal personnel:
• Align inspection strategy with risk and projected financial impact
• Develop a repeatable risk assessment across the entire organization
• Proactively evaluate how change of service may impact inspection schedules
• Reduce the risk of an unexpected failure
9 Jurisdictional Regulations for Tank Risk-Based Inspection
Tank RBI Methodology
RBI Expertise
Tank RBI follows API RP 581 to calculate risk using the probability of failure (POF)
and consequence of failure (COF) of the shell course and bottom.
As an RBI industry leader, we continue to foster innovation
POF: COF: by performing cutting-edge research and development into
Loss of Containment Effects of Loss of Containment
software tools and procedures to improve industry practices.
• Generic failure frequency • Financial consequence analysis
• Active damage mechanisms • Environmental clean-up, repair, &
• Management systems factor production
• Safety area (applicable only to
API RBI SagePlusTM
shell courses)
Equity Engineering Practices (EEPs)
Click for more information
All these procedures use data that is straightforward We use our knowledge of storage tanks, tank RBI, and tank
to determine and very basic to a tank’s design. FFS to help terminal and tank farm personnel with a facility’s
IMP. E²G’s multi-disciplinary subject matter experts (SMEs)
provide clients with a repeatable risk assessment that can
Tank Integrity Management Program (IMP)
be applied across an organization.
Expand your existing tank IMP to include a quantitative tank RBI program.
• Easily review and update risk assessments after inspections, and unplanned
events or on a set interval to help keep future inspections up to date
• Determine critical areas to concentrate inspection efforts by combining a
proactive tank fitness-for-service (FFS) review with a tank RBI assessment
• Evaluate the viability of a change of service program on a new or existing
tank farm and understand the impact on future inspection schedules
Damage Mechanism Reviews
Identifying damage mechanisms helps predict a tank’s remaining life and potential
risk for failure. During a damage mechanism review (DMR), we work with you to
identify active and potential damage mechanisms and use that data to calculate
the tank’s POF. Common storage tank damage mechanisms are: internal corrosion,
internal thinning, external corrosion, and corrosion under insulation (CUI).
ANSWERS FOR TODAY. INSIGHTS FOR TOMORROW.
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