Facility inspections are a key component of our spill prevention program. While compliance with our rules is certainly an area of focus during our inspections, we also use these opportunities to provide technical assistance to the regulated community. By working with the oil-handling industry, we collaborate on innovative ways to satisfy rule requirements and strive toward a common goal of preventing oil spills.
Routine inspections of oil-handling facilities are a strong component of Washington’s oil spill prevention efforts. We conduct regular facility inspections to ensure use of good operating practices and compliance with our rules. While enforcement is one way to drive compliance forward, our facility inspectors strive to work with the regulated community to provide technical assistance with proper implementation of Washington’s spill prevention rules. We work hard to serve as a resource for the oil-handling community, with a focus on professional interactions with industry and our stakeholders.
Class 1 facilities
Refinery and marine oil-handling terminal owners and operators can expect our inspectors to reach out to them each year to arrange a site inspection, which typically takes two to three hours to conduct. We employ a team of licensed, professional engineers who have experience working in and with the oil industry to carry out our Class 1 facility inspections.
We inspect each facility and their oil-handing operations for compliance with their approved plans and our rule, particularly the Class 1 facility design standards called out in the rule. The frequency of our Class 1 inspections varies, but owners and operators can generally expect one formal site inspection per year.
These inspections usually involve:
- On-site review of the facility’s inspection and maintenance records for storage tanks and transfer pipelines.
- Visual examination of dock operations and equipment, transfer pipeline systems, above-ground storage tanks, and secondary containment measures.
- On-site discussions between inspectors and facility staff at the time of the inspection.
- Follow-up written correspondence to document findings and recommendations.
Class 2 and 3 facilities
We inspect transfer operations at Class 2 and 3 facilities to ensure ongoing compliance with state and federal requirements for oil transfer facilities. These inspections are commonly referred to as transfer inspections. Transfer inspections are typically short in duration, less than an hour, and involve assessments of transfer equipment condition, maintenance records, and on-site operations.
Our inspectors use the Advance Notice of Transfer system to identify oil transfers for inspection purposes. Because oil transfer operations are limited in duration and do not tend to follow any set schedule, we do not pre-arrange transfer inspections with facility owners or operators. However, our transfer inspectors are experienced maritime professionals and do follow facility procedures for site access and entry.
For Class 2 facilities, the terms and conditions of the approved operations manual, training and certification program, and/or facility response plan may also be reviewed through an on-site inspection (there are presently no state requirements for these documents at Class 3 facilities). Site inspections associated with plan or program reviews are generally connected to the review and approval process, and are typically arranged with facility owners and operators ahead of the site visit.
Facilities can use our inspection checklist to verify that oil transfer procedures and equipment are in compliance with our rules.
Class 4 facilities
An annual inspection is also conducted at each Class 4 facility. These inspections are typically arranged beforehand by our inspectors and take around an hour or two to conduct.
Our main areas of focus are:
- Condition and status of oil transfer equipment.
- Response and recovery equipment.
- Training records.
- Spill notification information.
Our inspectors will review any issues found with the people in charge at the site and may send a letter detailing significant issues that are found during the inspection.
Facility owners and operators can use our Class 4 inspection checklist to learn what to expect during our inspections. Learn more about our requirements for oil-handling facilities in the Facility Oil Standards rule.