Hower Consulting Group, Inc. provides comprehensive tank management, inspection, and engineering services for aboveground storage tanks (ASTs) containing hazardous materials and hazardous waste. Hower Consulting has inspected and certified over 1,000 ASTs, providing peace of mind to tank owners with the reassurance that their tanks are in compliance with local, state, and federal safety and environmental standards.
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Spill Prevention Control and Countermeasure (SPCC) Plans - 40 CFR part 112

The Spill Prevention, Control, and Countermeasure (SPCC) regulation, also known as 40 CFR part 112, requires certain facilities to prepare, amend, and implement SPCC plans. The regulation sets forth requirements that SPCC plans must detail "the equipment, workforce, procedures, and steps to prevent, control and provide adequate countermeasures to a discharge" (EPA Guidance for Regional Inspectors, December 16, 2013). We provide several services for SPCC plans, including:
  • Preparation of SPCC plans - (40 CFR 112.7)
  • Amendments for SPCC plans - (40 CFR 112.5 (a))
  • Five-year review, evaluation, and re-certification of SPCC plans - (40 CFR 11(b))
  • Tank integrity testing and inspections - (40 CFR 112.8 (c) (6))
Our SPCC plans, amendments, and five-year reviews are complete, well organized, and easy to follow. They are prepared and certified by California registered professional engineers.

Regulations are being developed for California's Aboveground Petroleum Storage Act (APSA), formally known as Chapter 6.67 of the California Health and Safety Code. The federal (SPCC) and state (APSA) regulations vary slightly in applicability, but both require a written plan. It is important to know the differences between the California and the federal programs. For example, the Certified Unified Program Agency (CUPA) inspects facilities for SPCC plans under California law and the EPA inspects facilities under federal law. Another difference is that SPCC includes animal fats and vegetable oils, but APSA does not. It is important that SPCC plans include the correct tanks and containers, in addition to being complete and up to date.
Certified Steel Tank Institute (STI) Aboveground Storage Tank (AST) Inspections

The federal Spill Prevention, Control, and Countermeasure (SPCC) plans require integrity testing for ASTs. The integrity test requirement in each SPCC plan can be fulfilled for steel ASTs by using STI SP001: Standard for the Inspection of Aboveground Storage Tanks, along with another testing technique [40 CFR 112.8 (c) (6)]. The standard is used for shop-fabricated and field-erected tanks with a capacity of less than 50,000 gallons. Our inspections are done by STI-certified inspectors and include a short written report the day of the inspection, followed by a formal written report. Our STI inspections include:
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  • Review of tank records, drawings, and nameplate information
  • Evaluation of primary tank structure, including an assessment of the coating and corrosion protection (such as anodes)
  • Assessment of secondary containment and spill controls
  • Compliance evaluation with building codes and industry standards, especially for foundations, drainage, tank anchorage, and pipeline supports
  • Testing of leak detection, level gauge, and overfill equipment per manufacturer's specifications
  • Compliance evaluation with National Fire Protection Act (NFPA) 30 and 30A standards for venting, tank spacing, dispensing hoses, anti-siphon valves, emergency fire valves, and grounding and with NFPA 704 standards for signage
  • Verification that site is adequately lighted and secure
  • Measurement of the metal tank shell thickness and comparison to the original tank shell thickness, using ultrasonic measurements and annotating corrosion rate
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California Code of Regulations (CCR) Title 22 and Title 23 Professional Engineer (PE) Certfications for Hazardous Waste Tank Systems

California regulation CCR Title 22, Chapters 14 and 15 and Title 23 require that all hazardous waste tank systems be certified when installed, evaluated and recertified a minimum of every five years thereafter, and evaluated and recertified after a major repair. Hower Consulting Group, Inc. provides complete PE assessments and certifications for RCRA and non-RCRA hazardous waste tanks, including permitted treatment, storage, and disposal facilities (TSDFs). Our assessments include:
  • Evaluation of interior and exterior coating status via non-destructive testing inspections
  • Assessment of corrosion protection, including anode inspections
  • Evaluation of the secondary containment capacity and description regarding adequacy
  • Verifying that materials used in tank systems are compatible with the hazardous waste
  • Determining that tank anchorage and pipeline supports are adequate using Uniform Building Code, applying seismic importance factors, and ensuring calculations to support the site-specific requirements
  • Reviewing leak detection records and testing leak detection instruments
  • Evaluation of presence, type, and functionality of spill overfill prevention methods and instruments
Repair recommendations are provided for deficiencies found during assessments. Tank systems that are in compliance receive stamped and signed PE Certification reports. The reports document all Title 22 and Title 23 requirements and are organized for easy review by regulators. Our services don't end with a report. We support clients during Certified Unified Program Agency (CUPA) inspections, as well as provide letters and/or personal testimony to CUPAs on our clients' behalf.
Tank and Pipeline Repair, Replacement, Modifications and Upgrade Solutions

Many tank inspections uncover tank and pipeline deficiencies. Aging tanks and pipelines also require repairs and upgrades from time to time. Along with inspections, we provide comprehensive repair solutions to ensure that the correct equipment is supplied, that the project is cost effective, and that construction is done in compliance with safely regulations. Our repair solutions include:
  • Equipment sizing, specifications and selection
  • Design and cost estimates that are accurate and complete
  • Preparation of bid documents
  • Construction management to ensure a project is completed safely, on time, and on budget
  • Teaming with a construction firm to do the repairs in a timely and cost-effective way
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