Comment from CC Consulting and Management Solutions

To whom it may concern: CC Consulting & Management Solutions LLC appreciates the opportunity to comment on PHMSA’s proposed Breakout Tank Inspection Rule under 49 CFR Part 195. We support PHMSA’s proposal to update the incorporated edition of API Standard 653 and to allow the use of properly structured risk-based inspection procedures for in-service breakout tanks. In our view, this modernization can improve safety and environmental protection if implementation is supported by clear expectations for technical justification, documentation, operator accountability, and regulator review. Breakout tank inspection should not be treated only as a fixed calendar activity. Tank risk is influenced by service history, product characteristics, shell/bottom corrosion rates, previous repairs or alterations, settlement history, foundation condition, secondary containment condition, cathodic protection performance where applicable, inspection history, operating profile, spill history, management of change, and proximity to sensitive receptors or high-consequence areas. Risk-based inspection can be an effective integrity management tool when these factors are evaluated together and documented in a way that allows the operator, inspector, and regulator to understand why a specific inspection interval is appropriate. However, RBI should not become a mechanism for extending inspection intervals without a defensible technical basis. We recommend that PHMSA consider clarifying minimum elements expected in an operator’s RBI basis, including: 1. Documented tank service history and current product service; 2. Prior API 653 inspection results and repair history; 3. Corrosion-rate assumptions and supporting inspection data; 4. Settlement, foundation, and shell-to-bottom integrity considerations; 5. Secondary containment and drainage condition; 6. Operating history, including abnormal events, overfills, releases, repairs, or service changes; 7. Management-of-change review when product service, operating conditions, or tank configuration changes; 8. Qualifications of personnel performing the assessment; 9. Defined triggers that require reassessment before the next scheduled inspection; and 10. A clear record showing how the final inspection interval was selected. We also encourage PHMSA to emphasize that tank integrity is not only an engineering issue. It is also an operations, environmental, safety, and documentation issue. A technically sound inspection interval can be weakened if facility procedures, operator training, repair documentation, alarm management, containment management, or SPCC alignment are not maintained with the same discipline. For smaller operators, PHMSA may also wish to consider guidance or implementation tools that help translate RBI expectations into practical compliance steps without reducing safety expectations. Many operators may have inspection records and tank files, but not always a fully integrated process connecting API 653 inspection data with O&M procedures, SPCC plans, maintenance planning, and management-of-change documentation. In summary, CC Consulting & Management Solutions supports PHMSA’s effort to modernize breakout tank inspection requirements. Risk-based inspection can improve safety and focus resources on higher-risk assets, but only when it is technically justified, documented, periodically reassessed, and integrated into the operator’s broader integrity management and environmental compliance program. Respectfully submitted, Carlos Castillo CC Consulting & Management Solutions LLC