Regs aside, vinyl coatings inside or outside of tank should be removed, even if they appear to be perfect, as even a small defect can allow water to enter and be held between the tank and the coating.
The regs are simply not the issue as the liability will rest solely on the test facility if they pass a tank with a liner for the visual portion of the requalification and it then fails due to to pitting, line corrosion or widespread corrosion under the liner or coating. At that point there is no way they can prove the liner was perfect when they did the inspection, and the plaintiff and the DOT will assume the facility erred as the tank failed due to undiscovered rust under the liner.
The re-qualification stamp is also good for 5 years on the 3AA tanks in questions so the inspector is literally betting that the coating is intact, and will remain intact for the next 5 years. I'm not willing to do that and I would not *require* any tank inspector to pass a tank where it's simply more prudent to remove the liner or coating before agreeing to inspect/test the tank. Hydro facilities are not condemning tanks with the liners or coatings, they just are refusing to re-certify them until it's removed and that's pretty reasonable.
As noted previously, the newer linings are very smooth and very thin so any rust under them will be obvious - but that's not what we are talking about with any steel 72.
The regs are simply not the issue as the liability will rest solely on the test facility if they pass a tank with a liner for the visual portion of the requalification and it then fails due to to pitting, line corrosion or widespread corrosion under the liner or coating. At that point there is no way they can prove the liner was perfect when they did the inspection, and the plaintiff and the DOT will assume the facility erred as the tank failed due to undiscovered rust under the liner.
The re-qualification stamp is also good for 5 years on the 3AA tanks in questions so the inspector is literally betting that the coating is intact, and will remain intact for the next 5 years. I'm not willing to do that and I would not *require* any tank inspector to pass a tank where it's simply more prudent to remove the liner or coating before agreeing to inspect/test the tank. Hydro facilities are not condemning tanks with the liners or coatings, they just are refusing to re-certify them until it's removed and that's pretty reasonable.
As noted previously, the newer linings are very smooth and very thin so any rust under them will be obvious - but that's not what we are talking about with any steel 72.