Steel Tank Institute AST Inspections. Dana Schmidt, PE STI/SPFA

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1 Steel Tank Institute AST Inspections Dana Schmidt, PE STI/SPFA

2 Agenda Brief review of SPCC Rule SPCC relevance to small tanks and small facilities. SP001 Standard for Inspection of Aboveground Storage Tanks overview SP001 5 th Edition changes SP031 Standard for Repair of Shop-Fabricated Storage Tanks overview

3 What is SPCC Spill Prevention Control and Countermeasure (SPCC) rule 40 CFR part 112 Requires facilities to develop and implement SPCC Plan: Operating procedures to Prevent an oil discharge; Control measures to prevent an oil discharge from entering navigable waters; and Countermeasures to contain, clean up, and mitigate the effects of any oil discharge that affects navigable waters

4 Compliance Dates A facility starting operation On or before August 16, 2002 After August 16, 2002 through November 10, 2010 After November 10, 2010 (excluding production facilities) After November 10, 2010 (production facilities) Must Maintain existing Plan. Amend and implement revised Plan by November 10, 2010 Prepare and implement Plan by November 10, 2010 Prepare and implement Plan before beginning operations. Prepare and implement Plan within 6 months after beginning operations.*

5 What is OIL? Petroleum and Fuel Oils Gasoline Diesel Lube oils Aviation gasoline Jet fuel Naptha Mineral spirits Etc

6 What is OIL? Oil refuse Oil mixed with wastes Animal fats, oils, greases, vegetable oil (AFVO) Mineral oils Denatured ethanol

7 SPCC Rule Applicability If the total storage in containers (tanks) a. Aboveground > 1320 gallons b. Underground > 42,000 gallons (and not subject to UST Rule) 2. It is not a transportation related facility - which would fall under DOT 3. And there is a reasonable change of a discharge to waters of the U.S. or adjoining shorelines

8 Container size determination Storage capacity is defined as the shell capacity of the container Rated design capacity not the operational capacity Moving the overfill does not decrease capacity In containers with mixtures, total tank capacity is to be used, not % oil

9 Integrity Testing 112.8(c)(6) and (c)(6) Test/inspect each aboveground container for integrity on a regular schedule and whenever material repairs are made.

10 Integrity Testing You must determine, in accordance with industry standards Appropriate qualifications for personnel performing tests and inspections Frequency and type of testing and inspections which take into account container size, configuration, and design, such as containers that are: Shop built Skid-mounted Elevated 112.8(c)(6) and (c)(6) Equipped with a liner Double walled Partially buried

11 SPCC Rule and Industry Standards 112.3(d)(1)(iii) SPCC Plan requirements in accordance with good engineering practice, including consideration of applicable industry standards that procedures for required inspections and testing have been established Most PE s realize industry standards reduce liability

12 Environmental Equivalence Allows for deviations from specific rule requirements Owner/operator responsible to select, document and implement alternate measure PE certifies the SPCC Plan in accordance with good engineering practices, including consideration of industry standards 112.7(a)(2)

13 What does EE involve? Owner/Operator: Identifies reason to deviate from rule requirement Determines an alternate, environmentally equivalent method of spill prevention, control, or countermeasure Goal is to achieve the same desired outcome SPCC Plan includes: Reason for nonconformance Detailed description of the alternate method and how it achieves equivalent environmental protection EPA Regional Administrator has authority to require an amendment of the Plan

14 Qualified Facilities 112.3(g)(1) Tier I qualified facility 10,000 gallons or less total No container greater than 5,000 gallons Meets reportable discharge history criterion 112.3(g)(2) Tier II qualified facility 10,000 gallons or less total At least one container greater than 5,000 gallons Meets reportable discharge history criterion

15 Qualified Facilities An optional choice for small facilities: If And And.. Then A facility has been subject to SPCC for ten years or more; A facility has been subject to SPCC for less than ten years; (OR) A facility is new; has an aggregate aboveground oil storage capacity of 10,000 gallons or less; has an aggregate aboveground oil storage capacity of 10,000 gallons or less; had no reportable discharges during the ten years prior to selfcertification; had no reportable discharges since becoming subject to the SPCC requirements; the owner/operator can self-certify his/her SPCC Plan, without review and certification by a licensed Professional Engineer (PE).

16 Qualified Facilities Limits Do not use environmentally equivalent measures, Do not determine secondary containment to be impracticable, AND Do not need PE certification to comply with any rule requirements

17 Tier I Qualified Facilities Appendix G SPCC Plan template Streamlined Self-certified No P.E. required 112.3(g)(1) Does not need to include: Facility diagram Facility description Facility drainage Facility transfer operations Effluent treatment facility Loading/unloading rack Brittle fracture

18 Tier II Qualified Facilities 112.3(g)(2) Self-certified (no P.E. required) Integrity testing per industry standards

19 Tier II Qualified Facilities Hybrid Plans 112.3(g)(2) A Tier II SPCC plan with PE certified sections Allows use of E.E. and impracability determinations for containment so long as PE certified

20 STI SP001 5th Edition Standard for Inspection of Aboveground Storage Tanks Released Sept. 16, 2011

21 Inspection Based on Installation Type and Risk to Environment Tanks offering greatest risk have significantly more inspections Tanks with less risk have less inspections

22 SP001 Scope Ambient up to 200 F Atmospheric pressure

23 Facilities with a mix of tanks

24 Portable Containers (per SP001) Closed top AST 55 U.S. gallons or more and not intended for fixed installation Fills void in industry for inspection

25 Shop-Fabricated AST (per SP001) Welded metal AST fabricated in a manufacturing facility OR An AST without a nameplate with a volume less than or equal to 50,000 U.S. gallons

26 Field-erected AST (per SP001) Welded metal AST erected on-site where it will be used. Limited to a maximum shell height of 50 feet and a maximum diameter of 30 feet An AST without a nameplate that is more than 50,000 U.S. gallons and a maximum shell height of 50 feet and a maximum diameter of 30 feet

27 Spill Control Prevent release of liquid to environment Includes: Remote impounding Secondary containment dike/berm Secondary containment AST Secondary containment system

28 SP001 Key terms Release Prevention Barrier (RPB) Continuous Release Detection Method (CRDM)

29 Release Prevention Barrier (RPB) Liquid containment barrier Sufficiently impervious Under the AST Diverts leaks toward the perimeter of the AST where they can be easily detected

30 Continuous Release Detection Method (CRDM) A means of detecting a release of liquid through inherent design. It is passive because it does not require sensors or power to operate. Liquid releases are visually detected by facility operators. Tank with Release Prevention Barrier Secondary containment AST including double-wall ASTs Elevated AST with release prevention barrier

31 Elevated tanks with spill control now considered as CATEGORY 1 ELEVATED AST an AST which is not in contact with the ground and which is raised above the surface of the ground or bottom of a vault using tanks supports. An elevated AST allows for a visual external inspection of the bottom of the primary tank. Examples of elevated tanks are tanks constructed on grillage or grating, or tanks on supports.

32 Tanks with CRDM

33 Overfill Prevention additions 1.6 At a minimum, the following tank components shall be inspected (as applicable): Primary tank Secondary tank Tank supports Overfill valves and alarms OVERFILL PREVENTION - Systems, procedures or devices used to prevent liquid in ASTs from running over or spilling out of the AST during the filling process. A person who is physically present and in control of a shutoff device during the entire tank filling process is an acceptable procedure to achieve overfill protection.

34 Table 5.4 Example Categories Expanded

35 Category 1 Secondary containment and CRDM Double-wall Tank with Overfill Prevention Tanks in a Concrete Dike

36 Category 2 Secondary containment Tanks in earthen dike Dike prevents release due to catastrophic tank release only

37 Category 3 No Secondary Containment No RPB

38 Category 3 RPB, but no secondary containment

39 Initial Inspection 5.1 The owner shall use the AST s type, size and type of installation, corrosion rate and previous inspection history, if any, to develop a schedule of applicable types of inspections for each AST, per Table 5.5. The interval for the initial inspection shall begin from the AST s initial service date, if known. For the purposes of this requirement, the initial service date is the date on which liquid was first placed in the tank. If the initial service date is not known, the owner shall be responsible for establishing and documenting the initial service date.

40 Inspection Types Owner Monthly/Annual Inspections Check operation of vents, coating, foundation Formal External Inspections Certified inspector, but no entry Leak Test Determine if AST is leaking. Formal Internal Inspections Entry into tank is necessary for full assessment

41 Risk Matrix concept More Risk Tank Size Category 1 Category 2 Category 3 More Risk Shop built tanks P P P, E&L(10) ,000 5,001-30,000 30,001-50,000 P P, E&L(10) [P, E&L(5), I(10)] or [P, E(5) & L(2)] P, E(20) [P, E(10)& I(20)] or [P, E(5) & L(10)] [P, E&L(5), I(10)] or [P, E(5) & L(1)] P, E(20) P, E&L(5), I(15) P, E&L(5), I(10) Field erected P, E(5), I(10) P, E(5), I(10) P, E(5), I(10) Portable containers P P P **

42 Owner s inspections Monthly and Annual Containment area and foundation Shell coating Normal vents operation Emergency vents operation Tank level gauge Interstitial space monitor Overfill valves and alarms

43 Additions to checklists Monthly Checklist Tank valves Overfill equipment Ladder and platform Yearly Checklist Vents components freely move Anti-siphon, check, gate valves Press. Regulator Expansion relief Solenoid valve Fire / shear valve Leak detectors Filter / Strainer Overfill and liquid level equipment Labels and tags

44 Formal External and Formal Internal Inspections Performed by Qualified Tank Inspector STI Trained and Certified API 653 Adjunct Certified (with additional SP001 certification)

45 Formal External Inspections Containment area Stairways, ladders Normal vents Emergency vents Overfill alarms Fire valves UT of accessible areas, near base of tank (internal inspection if problems found)

46 Formal Internal Inspections Check all external inspection items UT of entire tank bottom elevated tanks do not require entry UT methods UTT point measurements (15 points per sq. ft.) UTS full scan if problems found in UTT

47 STI Inspector Certification Attend seminar Pass exam Visual acuity exam 5 year certification Over 750 certified STI inspectors

48 SP /2013 Certification dates Baltimore, MD: December 10 14, 2012 Baltimore, MD: April 29-May 3, 2013 Baltimore, MD: August 19-13, 2013 More dates at Certification Programs

49

50

51

52 Inspection Schedule/Table P Periodic Inspection by Owner E-External Inspection by Certified Inspector I-Internal Inspection L-Leak Test Shop built tank Size, Gallons Category 1 Category 2 Category P P P, E&L(10) ,000 5,001-30,000 30,001-50,000 P P, E&L(10) [P, E&L(5), I(10)] or [P, E(5) & L(2)] P, E(20) [P, E(10)& I(20)] or [P, E(5) & L(10)] [P, E&L(5), I(10)] or [P, E(5) & L(1)] P, E(20) P, E&L(5), I(15) P, E&L(5), I(10) Field Erect Tank P, E(5), I(20) P, E(5), I(20) P, E(5), I(20) Portable Containers P P P **

53

54 Insulated AST Remove insulation where moisture or product collects If vapor barrier damaged, remove sections of insulation

55

56 Inspection Schedule/Table P Periodic Inspection by Owner E-External Inspection by Certified Inspector I-Internal Inspection L-Leak Test Shop built tank Size, Gallons Category 1 Category 2 Category P P P, E&L(10) UST P as P, E&L(10) AST [P, E&L(5), I(10)] 5,000 or [P, E(5) and L(2)] 5,001 - P, E(20) [P, E(10)and I(20)] [P, E&L(5), I(10)] 30,000 or [P, E(5) and L(10)] or [P, E(5) and L(1)] 30,001-50,000 P, E(20) P, E&L(5), I(15) P, E&L(5), I(10) Field Erect Tank P, E(5), I(20) P, E(5), I(20) P, E(5), I(20) Portable Containers P P P **

57

58 Suitability for continued service MIC corrosion Repair immediately. Next inspection 2 years Category 3 less than 75% remaining, then repair. Next inspection 5 years Category 2 3 in 2 in a sq. ft. is less than 75% remaining, or less than 50%, then repair. Next inspection 5 years Category 1 3 in 2 in a sq. ft. is less than 50% remaining, or less than 25%, then repair. Next inspection 5 years 3 % Remaining

59 MIC corrosion

60 Why Develop a Repair Standard? Provide recommendations for safe repair of tanks Companion standard STI SP001 What do I do with a tank after it has been inspected? Can it be repaired? How can it be repaired?

61

62 What makes shop-fabricated tanks different? Shop-fabricated Typical Bottom or Head Field-erected Typical Bottom

63 SP031 Standard Organization 1.0 Scope 2.0 Definitions 3.0 Safety Considerations 4.0 Personnel Qualifications - Repair and Inspection 5.0 Materials and Welding 6.0 Modifications 7.0 Repairs 8.0 Testing

64 Scope Aboveground Tanks Flammable and Combustible Atmospheric Shop-fabricated carbon and stainless steel Built to national standards What is not included? Underground tanks to be used aboveground Field-erected tanks Bolted or riveted tanks Good engineering practice and experience

65 Scope Tank Owner Responsibilities Adherence with codes, standards, and regulations Responsible that individuals working on tanks can understand and address the hazards Repair or modification may impact Listing Limited to tank wall, supports, connections, nozzles, manways Does not cover attachments to tank such as catwalks, platforms, etc.

66 Safety The hazards associated with the cleaning, entry, inspection, testing, maintenance or other aspects of ASTs are significant. Safety considerations and controls should be established prior to undertaking physical activities associated with ASTs. Each AST entry requires an Emergency Action Plan. NFPA and API Industry Standards OSHA requirements Minimum Entry Tests for O 2, LEL, CO, H 2 S

67 Safety Hazards with Flammable and Combustible Tanks Fires Explosions Suffocation Releases to the Environment

68 SP031 Personnel Qualifications Repair/Modify Manufacturer of Labeled/Listed Tanks ASME Section IX AWS D1.1 Tester experience with methods Final Inspection STI SP001 API 653 Manufacturer of Labeled/Listed Tanks

69 Repairs at knuckle Limited repairs in knuckle area Otherwise, replace the bottom or head.

70 Shell Repairs Lap weld patch plates Insert plates Shape Existing welds spacing

71 Modifications Section New pipe connections Reinforcing plate when pipe >2 Manways Reinforcing plate when below liquid level New second bottom Knuckle at bottom Increase Shell Height Anchor Chair Addition

72 Bottom Repairs

73 Testing Requirements Testing of all repairs and modifications required Significant repair examples (requires tank pressure test) Complete replacement of bottom Patch plate greater than 12 square feet Openings greater than 12 inches diameter Final inspection by SP001 inspector or tank manufacturer

74 Available in Publications Index at SP001 and SP031 available together at a discounted price Technical Questions STI Engineer and Staff Liaison Dana Schmidt ext 246

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