Attachment 3 - API Report Tank 2.pdf

Preliminary Report

PRELIMINARY INSPECTION REPORT

API 653 OFF-STREAM INSPECTION

Client ECC Romania

Tank Number TK2

Location Mihail Kogălniceanu, Romania

Project Number 3-4000-10970

Report Number FR-40-MIH-TK2-20170930-0

Revision Number 0

Inspection Date September 27, 2017 till September 28, 2017

Revision Date September 30, 2017

Client: Name: ECC Romania ROSEN Project No.: 3-4000-10970 Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

This document is classified as confidential ROSEN · page 2 of 55

ROSEN Europe B.V.

NDT Diagnostic Zutphenstraat 15 7575 EJ Oldenzaal Netherlands

Phone +31 (0) 541 671 477 Fax +31 (0) 541 671 130 bsilva@rosen-group.com www.rosen-group.com

Prepared by

L.M.E. Schmidt API 653 Tank Inspector, Cert. no. 62883 API 570 Piping Inspector, Cert. no. 38038 STI SP001 Cert. No. AC 44157 EEMUA 159 Tank Assessor, Cert. no. 54663 UTT level II, Cert. No. C14021003

Checked by

Ivo Peddemors API 653 Tank Inspector, Cert. no. 44333 STI SP001 Cert. No. AC 44075 EEMUA 159 Tank Assessor, Cert. no. 10ND/10TA/151 UT level II, Cert. No. N30381

Approved by

Bibiana Silva Project Manager

0 30-Sep-2017 55 Preliminary Report L.M.E. Schmidt

Rev. Date Pages Description Prepared by Checked by Approved by

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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TABLE OF CONTENTS

1 MANAGEMENT SUMMARY 5

1.1 Actions/recommendations 8

1.2 Corrosion rates and next inspection date 9

1.2.1 Next inspection date

2 INTRODUCTION 12

2.1 General 12

2.2 References 12

3 TANK DETAILS 13

4 SAFETY REPORT 16

4.1 Tank Isolation 16

4.2 Safe Entry 16

4.3 Roof Support 16

4.4 Falling Object Hazards 17

4.5 Tripping and Slipping Hazards 17

4.6 Roof Plate Thickness 17

4.7 Stair and Walkway 18

5 BOTTOM INSPECTION REPORT 19

5.1 Cleaning of Tank Bottom 19

5.2 Bottom Plate Construction 19

5.3 Bottom Lining 20

5.4 Bottom Plate Condition 21

5.5 Bottom Plate Condition Outside Tank 22

5.6 Condition of Bottom Welds 23

5.6 Condition of Bottom Welds Continued 24

5.7 Bottom Plate Settlement 25

5.8 Bottom Sump 25

5.8 Bottom Sump Continued 26

5.9 Bottom Attachments 26

5.9 Bottom Attachments Continued 27

5.10 Cathodic Protection of Tank(bottom) 28

6 SHELL REPORT 29

6.1 Shell Construction 29

6.2 Shell Exterior Condition 30

6.3 Shell Interior Condition and Liner 31

6.4 Wind Girders, Shell Stiffeners and Curb Angle 32

6.5 Shell Appurtenances 33

6.6 Foundation / LDS 34

6.6 Foundation / LDS Continued 35

7 FIXED ROOF REPORT 36

7.1 Fixed Roof Type 36

7.2 Fixed Roof Plate Condition 37

7.3 Fixed Roof Supports 38

7.4 Fixed Roof Appurtenances 38

7.5 Fixed Roof Appurtenances Continued 39

7.4 Fixed Roof Appurtenances Continued 40

7.5 Roof-to-Shell Joint 40

8 INTERNAL EQUIPMENT 41

8.1 Diffusers/Air Rolling Systems 41

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

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8.2 Roof Drains 41

8.3 Internal Piping 42

8.4 Internal Floating Cover (IFC) 43

9 EXTERNAL EQUIPMENT 44

9.1 External Piping and Valves (secondary containement area) 44

9.1 External Piping and Valves (secondary containement area) Continued 45

9.2 Access Structure 45

9.2 Access Structure 46

9.3 Pressure - Vacuum Vents and Breather Valves 46

9.3 Pressure - Vacuum Vents and Breather Valves Continued 47

9.4 Level Alarm System 48

9.5 Site and Dike Inspection 50

9.5 Site and Dike Inspection Continued 51

9.6 Fire Fighting Equipment 52

9.7 Grounding of Tank and auxiliary equipment 53

9.8 Tank Instruments 54

10 ABBREVIATIONS 55

APPENDIX A: TANK BOTTOM RESULTS

APPENDIX B: MEASUREMENT RESULTS

APPENDIX C: COMPLIANCE CALCULATION RESULTS

APPENDIX D: API 653 CHECKLIST

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

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1 MANAGEMENT SUMMARY

General The condition of tank 2, located within the containment area (Facility number P7004) and within at the Bulk Fuel Point, at the 34th BDE Base in Mihail Kogălniceanu, Romania has been inspected by the Survey Engineer(s) by means of a Detailed Visual Inspection (DVI) in combination with necessary NDT equipment. This DVI includes inspection of the tank exterior and interior as required for an API653 compliance check. Evidence of leaks, shell distortions, signs of settlement, corrosion, condition of the foundation, coating coatings, insulation systems, and appurtenances have been documented for follow-up action by the authorized API 653 inspector if deemed necessary. The survey has been concluded on 27 and 28 September, 2017. This section provides a summary of the inspection findings. Finding details are reported in this document under correspondent section.

Variant name / location / photographs / conversion For the tank’s north direction, manhole A1 has been used, this does not correspond with the geographical North.

Pictures shown in this report were edited using image-processing application to enhance visibility and richness of detail.

Measurements were taken in metric values (SI). Conversion to US values, where necessary, were made using 1mm = 0.03937“, 1m = 3.2808`. US values in [Brackets].

General Condition Tank 2, is a steel Aboveground Storage Tank (AST) with the intended service of the storage of JP-8 (F- 34). Since construction in 2009 the tank has not yet been in service. The tank is resting and a concrete ring beam and has an Under Tank Leak Detection installed. The bund floor of the secondary containment area is constructed out concrete. As per received design drawing there is no liner installed in the secondary containment area. The concrete wall 1.6m high and floor of the secondary containment area are cracked at several locations and are therefore not considered impermeable.

The tank has a diameter of 9.545m and a height of 11.864m.

The design is API 650 10th edition addendum 3, including Appendixes B, E, F, H, I. according the nameplate present. Assumption is that all NDT has been performed during construction.

It has been noticed that the tank is not equipped with an internal floating cover nor independent fire-fighting equipment on the tank and / or secondary containment area.

Brittle Fracture consideration The lowest recorded temperature at Constanta weather station: 14 m.a.s.l (meter above sea level., 21.0 km away from Mihail Kogălniceanu level is -20.3 degrees Celsius. (Source: YR.no) The tank is designed conform API 650 10th edition, 3rd addendum. Therefore the assumption is that the brittle fracture considerations have been taken in account during the design of the tank. Furthermore the brittle fracture assessment conform API 653 fig 5.1 indicates that there is a low risk of brittle fracture. Also when applying a LODMAT of -30°C Degrees at the request of ECC the risk is stated as low. Therefore Rosen does not see the need to perform a brittle fracture assessment against European Codes as request by ECC especially there the tank is designed conform API 650 10th edition, 3rd addendum.

Note: The Design Metal Temperate is not the same as the out-side air temperature, when a tank contains product the tank shell will have a temperature between the out-side air temperature and product temperature.

Seismic Load:

According to the nameplate this tank has been constructed in accordance with API 650 10th edition addendum 3, including Appendixes B, E, F, H, I. Therefore it is assumed that the Seismic design of storage tanks has been applied. The inspection and NDE performed did not indicate a change has occurred from the original physical condition of the tank and therefore it can be assumed that the seismic evaluation which has been applied during the design phase is applicable.

For further details see the separate report Seismic Assessment of Tank 2.

Safety Tank was electrically isolated and the valves were in closed position and no safety concerns observed.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

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Bottom The bottom was sufficient clean to perform a visual and a MFL inspection.

There is a butt welded annular ring installed and the bottom plate rows are lap welded. The bottom plates within one and the same row are lap welded.

The bottom has been inspected by means of an MFL/EC scan (ROSEN TBIT). In total, zero (0) metal loss indications have been recorded in the bottom of the tank, exceeding the reporting threshold of 20%t metal loss. Assessment has shown that the repair threshold is 52%t metal loss for the bottom plates and 39%t metal loss for the annular plates, this means that the tank bottom is in compliance with API 653 at the time of inspection. The liner is in a good condition, and no limitations for continued service have been observed. Taking the thin film liner and the leak detection system into account, no repairs are required for a next service period of 5 years. Refer to Appendix A.

The bottom projection has a drip ring installed to prevent rain water penetrating underneath the tank bottom. Minor coating damage observed to the external bottom projection, only the top layer is affected.

In agreement with the ECC representative it has been agreed, that no magnetic particle inspection (MPI) was performed on the corner weld and the sump weld, due to the applied liner on these welds.

The welds have been visually inspected with the liner still applied. Generally the welds appear to be in a good condition nevertheless undercut / remaining slag is present and observed scattered over the entire circumference of the bottom-to-shell weld of the tank. The on-site ECC representative has been made aware of this. It is recommended to remove the undercut / slag by means of grinding and perform MPI and weld profiling measurements afterwards to assure no cracks are present in the area and the weld profile meets the requirements of API 650 section 5.1.5.7.

The measurements of the internal and external bottom projection are within acceptable limits of API 653 section 4.4, nevertheless minor coating failure has been observed to the external bottom projection.

A laser survey has been performed to measure the bottom slope and edge settlement. All measurements are within API 653 rejection limits.

The sump is covered with a lining, which is in good condition. UT spot measurements did not reveal wall thinning of the bottom sump.

The internal piping supports are equipped with a bearing pads. Not at all bearing pads the minimum weld spacing requirements were taken in consideration.

The tank bottom is not equipped with a cathodic protection system. The tank has 4 earth cables ø8.0mm connected, unknown when the last annual resistance check has been performed.

Shell The shell is constructed out of eight (8) butt welded steel plates. UT spot measurements did not reveal any general wall thinning.

Assessment has shown that the shell is strong enough to withstand the liquid load of the stored the product (and during hydro test) when the tank is completely filled (spec. gravity product: 0.84, joint efficiency factor: 1.0).

The shell is coated internally and externally. The coating is in a good condition except at the high and high-level openings, localized coating damage with starting surface corrosion has been observed from the tank floor.

No anomalies have been observed to the curb angle. Assessment has shown that the tank does not require intermediate wind stiffeners.

Shell appurtenances attached to the shell are in good condition. UT spot measurements did not reveal any general thinning.

Localized minor coating failure has been observed to the nozzle neck, flanges and reinforcing plates of the manholes. The rust level has been estimated to be Ri2 according to ISO 4628-3, which is described as “no anomaly”.

Were reinforcement plates have been applied they are equipped with tell-tale holes of ø 6.0mm, however the reinforcement plate of the both man ways or constructed out of two segments, it is unknown if the butt

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

This document is classified as confidential ROSEN · page 7 of 55 weld connecting both segments is a full penetration weld and has fused with the original shell plate. The upper segment does not have a tell-tale hole.

The foundation has a height of ~600mm (2ft) and is expected to be in a good condition since the tank has not been in service yet. The concrete ring beam is not visible since the foundation is sloped with compacted sub-grade and paved with concrete.

Fixed Roof Minor localized coating failure and starting corrosion was noted on the roof deck and appurtenances. The rust level has been estimated to be Ri2 according to ISO 4628-3, which is described as “no anomaly”.

Mainly the top-layer is flaking off.

UT spot measurements did not reveal wall thinning of the roof deck and appurtenances plates. During the inspection it has been observed that the roof deck plates are constructed in such way that condense water may entrap in the crevice of the overlap to the underside of the tank roof.

The Tank roof is equipped the following appurtenances: One (1) 24” free vent, one (1) 35½” manhole, four

(4) rectangular circulation vents 19*27½”, one (1) 8” blind nozzle, two (2) 8” sample hatches of which one

(1) is installed on the cover-plate of the manhole.

Assessment has shown that the roof-to-shell weld is not frangible. As per API 2000 emergency venting shall be installed if a tank is not frangible, due to the presence of the four (4) rectangular Circulation vents 19*27½” the emergency venting requirements are met.

The roof structure has been visually inspected from the ground floor. No distortion or damaged members of the roof was observed. Taking into account that the roof is internally coated and no corrosion has been observed form the roof plates. The inspector does not see the necessity of further detailed investigation of the roof structure.

Internal Equipment The diffuser is made from carbon steel and has minimum a thickness of ~7.8mm. No signs of degradation have been observed.

Ultrasonic spot measurements did not reveal major wall thinning, minor deviations were observed during the ultrasonic measurements presumably due to milling tolerances. Coating appears in good condition.

Although there are circulation vents present, the tank is not equipped with an internal floating cover.

External Equipment On the external piping system (inlet, outlet, pressure relieve system and water draw-off piping) the following observations have been made:

- Minor localized coating failure and starting corrosion with minor metal loss 0.5mm deep is present.

- Assumption is that all valves installed are conform the received design drawing.

The access structure to the secondary containment is in good and safe condition. Nevertheless the grating of the walk-ways is not anchored. Minor coating failure to underside of top-landing of staircase.

The hinges of the sample hatches are not “running” free.

The davit of the man-way cover is not greased.

The free vent and circulation vents are equipped with a screen to prevent foreign objects entering the tank and the maze mesh meets the API requirements.

The reinforcement plates on the tank roof are equipped with telltale hole, due to the “horizontal pane” of the reinforcement plate rain water can entrap and cause crevice corrosion to the roof deck plate.

The tank is equipped with a low, high and high-high level switches. In the event the high-high level is reached an alarm will sound at the CCR. Unknown when the last function test has been performed.

The tank is resting and a concrete ring beam and has an Under Tank Leak Detection installed. The bund floor of the secondary containment area is constructed out concrete. As per received design drawing there is no liner installed in the secondary containment area. The concrete wall 1.6m high and floor of the secondary containment area are cracked at several locations and are therefore not considered

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

This document is classified as confidential ROSEN · page 8 of 55 impermeable. Were the import and export piping penetrate the bund wall there is no jacket pipe present and also no link-seal. Light vegetation was noticed within the secondary containment area.

The tank is not equipped with fire-fighting equipment but has a nozzle on the top-shell course for installation of foam piping.

Four grounding cables are equally spaced attached to the first shell course.

Light poles are present at landing platforms of the staircase. Lights were not activated since the inspection was performed during day-time.

1.1 Actions/recommendations

Mandatory Repairs Group 1 – Required repairs to return the facility to service:

The following items below are directly structural integrity related repairs and require repair prior the tank can return to service.

1) No structural integrity related concerns were observed during the inspection.

The following items below are not directly structural integrity related repairs but are repairs / actions to allow safe operation of the tank; taking in consideration that the tank will be used to store JP-8 (F-34).

2) Install an independent fire-fighting system for the tank as well as for the secondary containment area.

3) Perform annual resistance checks of the Earthing. The total resistance from the tank to earth potential should not exceed approximately 25 Ohms as per API 575 3rd edition section 8.2.5., also see

API 545.

4) Install an Internal Floating Cover to meet the local emission legislation and to minimize the explosion hazard in the vapor space. USACE - Item not to be included in project. Item previously installed via separate task order.

Mandatory Repairs Group 2 – Repairs that can be performed while the facility is in service The following items below are directly structural integrity related repairs and require repair prior the tank can return to service.

5) No structural integrity related concerns were observed during the inspection.

The following items below are not directly structural integrity related repairs but are repairs / actions to allow safe operation of the tank; taking in consideration that the tank will be used to store JP-8 (F-34).

6) Perform repairs to the bund wall and floor of the secondary containment area, since in its current condition it is not deemed impermeable. Detailed assessment has been made by ECC prior to the API 653 inspection.

7) Consider to apply a jacket sleeve with the use of a link-seal at bund wall penetrations.

e7ppemlt Line e7ppemlt Line e7ppebmp Line e7ppebmp Line e7ppebmp Line e7ppebmp Typewritten Text Contractor to correct any ground resistance deficiencies.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

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Recommended Repairs: – Repairs recommended but not required to return the facility to service.

8) It is recommended to remove the undercut / slag by means of grinding and perform MPI , and perform weld profiling measurements afterwards to assure no cracks are present in the area and the weld profile meets the requirements of API 650 section 5.1.5.7t around the circumference of the tank.

9) Give service to the sample hatches, grease rotating parts.

10) Grease the Davits of the man-way’s.

11) Remove loose coating and surface corrosion to the external as well internal tank bottom / shell / roof including all appurtenances and re-apply protective coating by means of localized coating repair.(~ 15m2) as well to the piping system within the secondary containment area.

12) Install one telltale hole in each upper segment of the two reinforcement plates of the man-ways on the tank shell.

13) Seal the tell-tale holes on the reinforcement plates present on the tank roof since water may entrap and cause crevice corrosion. During routine inspection by terminal personnel the bolts shall be remove and the telltale hole shall be checked for signs of leakage, after the inspection the bolts shall be installed again.

14) During the routine inspections the leak detection system should be checked whether product is in the system or not. USACE - Item not required.

15) Perform maintenance / function test of the all the level switches.

16) Perform maintenance / function test of all rotating equipment prior to taking the tank into service.

17) Install anchorage at the grating of the walk-way into the secondary containment area.

18) Accept deviation from design code or replace none compliant bearing pads for meeting the requirements of API 650 / 653. USACE - Non-compliant bearing pads shall be removed and replaced.

19) Remove vegetation from the secondary containment area.

20) Remove water from light fixture at the top land of the staircase, replace seals of light fixtures and perform function test of lighting (E&I).

Future Recommended Repairs: – Repairs that can be performed at the next inspection.

21) Perform regular (e.g. once every year) UT inspection of the roof deck plates at the “lap” to determine if crevice corrosion is occurring at the “lap” area.

22) After the next off-stream inspection perform a corrosion assessment and remaining life calculation for the bottom. If severe corrosion is found at the next inspection is should be considered to install a Cathodic Protection System

1.2 Corrosion rates and next inspection date

Shell corrosion rate and life expectancy (API 653, sect. 4.3.3)

C o u rs e N o

O r i g in a l W

T

[m m m in

W e a s.

m

C R m e a s

[m m

/y

W t m in a ll o w a b le

[m

C A m m

R L

C

A /C

R m a x

[y e a rs

E x te rn a l

In sp e ct io n

[y a rs

U in sp e ct io n

[y a rs

8 8 7.8 0.025 2.54 5.26 105.2 52.6 105.2

7 8 7.9 0.0125 2.54 5.36 107.2 107.2 214.4

6 8 7.9 0.013 2.54 5.36 107.2 107.2 214.4

5 8 8 0.000 2.54 5.46 109.2 27.3 54.6

4 8 7.9 0.013 2.54 5.36 107.2 107.2 214.4

3 8 7.8 0.025 2.54 5.26 105.2 52.6 105.2

2 8 8 0.000 2.54 5.46 109.2 27.3 54.6

1(bottom) 8 8 0.000 2.54 5.46 109.2 27.3 54.6

Maximum

CR:

0.05 Maximum Allowable:

5 15

Bottom corrosion rate and life expectancy (API 653, sect. 4.4.5) e7ppemlt Line e7ppemlt Line e7ppebmp Cross-Out e7ppebmp Cross-Out e7ppebmp Cross-Out

Date of Inspection: 27 / 28 September 2017 Revision No.: 0 Tank Number: TK 2 Location: 34th BDE Base in Mihail Kogălniceanu

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Note: a conservative general corrosion rate of 0.05 mm/yr has been used.

Remaining Life Assessment as per ROSEN (note 3) Internal Corrosion Assessment Bottom Annular M ax. wall loss measured %t 20% M ax. wall loss measured %t 20%

M ax. wall loss measured mm 1.6 M ax. wall loss measured mm 2.4

RWT prior repair mm 6.4 RWT prior repair mm 9.6

Number o f years installed years 8 Number of years installed years 8

Corrosion Rate CR (pitting) mm/y 0.200 Corrosion Rate CR (pitting) mm/y 0.300

Corrosion Rate CR (general) mm/y 0.05 Corrosion Rate CR (general) mm/y 0.050

Actual Corrosion Rate mm/y 0.250 Actual Corrosion Rate mm/y 0.350

Corrosion Rate used mm/y 0.350 Corrosion Rate used mm/y 0.350

Rejection limit WTs,min mm 1.27 Rejection limit WTa,min mm 4.32

Repair threshold applied 52% Repair thresho ld applied 39%

RWT after repair mm 6.4 RWT after repair mm 9.6

Corrosion Allowance CA mm 5.1 Corrosion A llowance CA mm 5.3

RL (bo ttom), max years 14.7 RL (annular), max years 15.1

Safety Facto r є[0,1] 1 Safety Facto r є[0,1] 1.0

M II (Internal bottom) years 14.7 M II (Internal annular) years 15.1

External Corrosion Bottom Annular M ax. wall loss measured %t 20% M ax. wall loss measured %t 20%

M ax. wall loss measured mm 1.6 M ax. wall loss measured mm 2.4

RWT prior repair mm 6.4 RWT prior repair mm 9.6

Number o f years installed years 8 Number of years installed years 8

Corrosion Rate CR (pitting) mm/y 0.200 Corrosion Rate CR (pitting) mm/y 0.300

Corrosion Rate CR (general) mm/y 0.050 Corrosion Rate CR (general) mm/y 0.050

Actual Corrosion Rate mm/y 0.250 Actual Corrosion Rate mm/y 0.350

Corrosion Rate used mm/y 0.350 Corrosion Rate used mm/y 0.350

Rejection limit WTs,min mm 1.27 Rejection limit WTa,min mm 4.32

Repair threshold applied mm 52% Repair thresho ld applied mm 39%

RWT after repair mm 6.4 RWT after repair mm 9.6

Corrosion Allowance CA mm 5.1 Corrosion A llowance CA mm 5.3

RL (bo ttom), max years 14.7 RL (annular), max years 15.1

Safety Facto r є[0,1] 1 Safety Facto r є[0,1] 1.0

M II (External bottom) years 14.7 M II (External annular) years 15.1

Abreviations RWT Prior Repairs: minimum remaining wall thickness at the time of the inspection.

CR: Corrosion Rate RWT After Repairs: minimum remaining thickness of the features that were not repaired.RWT after repairs : Remaining Wall Thickness of non-repaired features

RL: Remaining Life CA: Corrosion Allowance MII: Maximum inspection Interval

Note: The max. wall loss measured refers to the average o f the 5 deepest features. These measurements are used to calculate the corrosion o f the complete tank bottom internal and external.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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1.2.1 Next inspection date

The recommended next inspection date are only valid if the required and recommended actions described in this document are followed up and/or installed properly.

Inspection frequency based on API 653, chapter 6. Local authorities or national legislation may require a different inspection period.

Periodic in-service inspection by facility personnel (API 653, sect. 6.3.1):

Every month.

External inspection by a certified inspector (API 653, sect. 6.3.2):

September, 2022.

Ultrasonic thickness inspection of the shell (API 653, sect. 6.3.3):

September, 2032.

Internal inspection by a certified inspector(API 653, sect. 6.4):

September, 2027.

Based on the fact that the tank has not yet been in-service, the current inspection is seen as a base-line inspection and the next inspection as the initial inspection after 10 years as per API 653 section 6.4.2.1

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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2 INTRODUCTION

2.1 General

This inspection report describes the API 653 tank inspection survey carried out by Rosen Europe for ECC at tank 2, located within the secondary containment area (Facility number P7004) and within at the Bulk Fuel Point , at the 34th BDE Base in Mihail Kogălniceanu, Romania on September 27th and 28th, 2017.

This inspection report should be read in conjunction with API 653, particularly if the reader is not familiar with this Standard and the terms used in it, as some terms are particular to the Standard. We have exercised and applied API 653 in good faith and provide/present all details in accordance with this Standard.

However, the API 653 is not to be interpreted as approving, recommending, or endorsing any specific design or limiting the methods of inspection, repair, alteration, or reconstruction. Deviations to this standard will only be applied when seems necessary and will be conform to one of the standards as given in section 2.2 of this report and after consulting the Customer. In all cases, the technical integrity of the tank under consideration will be safeguarded.

Evaluation for structural integrity of areas that do not meet the Standard is often case-by-case and depends on the available information. For information not available or provided, assumptions have been made on basis of best experiences within our Company. Where necessary, our engineers will recognize and report whether a more dedicated (tank construction) engineering judgment is required. Additionally, we are receptive to any request from the Customer to reprocess the tank data in accordance with their differing interpretation of the API 653 standard.

2.2 References

The latest editions of the following standards were used during the inspection and for the preparation of this report:

1) API RP 575, "Inspection of Atmospheric and Low-Pressure Storage Tanks"

2) API RP 651, “Cathodic Protection of Aboveground Petroleum Storage Tanks”

3) API RP 652, “Lining of Aboveground Petroleum Storage Tank Bottoms”

4) API 653, "Tank Inspection, Repair, Alteration and Reconstruction”

5) API 2015, "Safe Entry and Cleaning of Petroleum Storage Tanks"

6) API 2000, “Venting Atmospheric and Low-Pressure Storage Tanks”

7) TI X147 NDT Instruction UT-01, ROSEN procedure, “Procedure for Wall Thickness Measurements of Steel.

8) TI F332 NDT Instruction MFL-01 (TBIT), ROSEN procedure, “Procedure for the flux leakage examination of ferromagnetic tank bottom sketch and annular plates using Rosen’s tank Bottom inspection Tool (TBIT)”.

9) EN 13018, “Non-destructive testing – Visual testing – general principles”

10) EN 13927, “Non-destructive testing – Visual testing – Equipment”

11) EN 9934, “Non-destructive testing – magnetic particle testing – parts 1 to 3”

12) EN 1593, “Non-destructive testing – Leak testing – Bubble emission techniques”

13) EN14015, The European Standard EN 14015, “Specification for the design and manufacture of site built, vertical, cylindrical, flat-bottomed, above ground, welded, steel tanks for the storage of liquids at ambient temperature and above”

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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3 TANK DETAILS

- Overview of tank 2, Facility number P7004 -

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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The following is a brief summary of the tank details. Other parameters are included in the document where relevant.

General

Tank number 2 Facility P7004

Tank type FRT

Design Standard API 650 10th edition addendum 3, including Appendixes B, E, F, H, I.

Construction year 2009

Manufacture Havatek Makina Sanayi Ve

Ticaret A.Ş.

Name plate present? [y/n] Yes

As built drawings available? [y/n] Yes NDT results from erection are not present

Dimensions

Diameter [m] 9.545m [31` 3.3ʺ]

Bottom surface [m²] ~71.56 m² [~770.27 ft2]

Height [m] 11.864m [~38` 9.2ʺ]

Maximum filling height [m] 10.900m [~37` 7.6ʺ]

Foundation

Type Concrete Ring

Leak detection present [y/n] Yes

Bottom

Installed year 2009

Nominal thickness plates [mm] 8.0 [0.315 ʺ]

Construction Lap-welded

Annular Ring Present [y/n] Yes

Annular Nominal Thickness [mm] 12.0 [0.472”]

Annular Plate Width [mm] 915 Minimum width

Internal Coating [y/n] Yes Thin film coating

Shell

Main Material ASTM S 275 JR

Construction Butt-welded

Internal Coated? [y/n] Yes

Height/Thickness Course 8 [m/mm] 1.480 / 8.0

Height/Thickness Course 7 [m/mm] 1.480 / 8.0

Height/Thickness Course 6 [m/mm] 1.480 / 8.0

Height/Thickness Course 5 [m/mm] 1.480 / 8.0

Height/Thickness Course 4 [m/mm] 1.480 / 8.0

Height/Thickness Course 3 [m/mm] 1.480 / 8.0

Height/Thickness Course 2 [m/mm] 1.480 / 8.0

Height/Thickness Course 1 [m/mm] 1.480 / 8.0

Wind Stiffener Installed? [y/n] No

Top curb angle dimensions [mm] 70x70x6.9mm

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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Roof

Roof type Cone

Spacing between radial beams 1.87m

Construction Lap-welded

Roof slope [°] 6.3°

Internal coated [y/n] Yes

Operational

Product Stored JP-8 (F-34) Jet Fuel

Gravity of Product 0.84

Storage Temperature [°C] ambient

Pressure / Vacuum range [mbar] 7.5 / 2.5

Anchored [y/n] Yes, 20x M32 Bolts

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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4 SAFETY REPORT

4.1 Tank Isolation

(API 2015 & API 653, Table C-2)

Visual Inspection Blinding of lines

Electrical disconnection

Line valves closed

Pump Electrically disconnected Comments: None.

Recommendations: None.

4.2 Safe Entry

Visual Inspection Confined Space Entry Permit

Vapor and gas freeing

Cleanliness

Adequate venting

Comments: Tank has never been in-service since erection.

Recommendation: None.

4.3 Roof Support

Visual Inspection Adequate fixed roof support structure

Adequate floating roof support legs

Comments: None.

Recommendations: None.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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4.4 Falling Object Hazards

Visual Inspection Falling scale

Product in appurtenances

Corrode through roof structure

Loose Items Comments: Loose threaded end-cap observed on staircase at high and high-high level switches. Loose item was taken to base of the tank by Rosen Engineers.

Recommendations: When disconnecting end-caps for bleeding off and / or sampling, reconnect them afterwards to prevent them from becoming a loose items with a potential hazard for falling objects.

4.5 Tripping and Slipping Hazards

(API 653, Table C-2)

Visual Inspection Obstructions

Presence of ice

Liquids on deck plate

Recommendations: None

4.6 Roof Plate Thickness

Visual Inspection Checked plate thickness before accessing

Ultrasonic Thickness Gauge roof.

Checked support structure before from tank floor before accessing roof.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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4.7 Stair and Walkway

Visual Inspection Check stair-walkway before access

Hammer Test Checked structural welds

Ultrasonic Thickness Gauge

Comments:

Access structures of the tank in good and safe condition.

The access structure to the secondary containment is in good and safe condition. Nevertheless the grating of the walk-ways are not anchored.

Recommended Repairs: – Repairs recommended but not required to return the facility to service.

Install anchorage at the grating of the walk-way into the secondary containment area.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5 BOTTOM INSPECTION REPORT

5.1 Cleaning of Tank Bottom

(API RP 575, Section 7.1 Preparations for Inspections)

Visual Inspection Grid-blasted

Washed

Scale present

Tack welds present

Comments: The bottom was sufficient clean to perform a visual and a MFL inspection.

5.2 Bottom Plate Construction

(API 650, Section 5 - Design)

Visual Inspection

Lap welded Sketch plates Butt welded Sketch plates

Riveted Sketch plates Butt welded annular ring

Riveted Annular plates Patch plates present

Comments: There is a butt welded annular ring installed and the bottom plate rows are lap welded. The bottom plates within one and the same row are butt welded.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.3 Bottom Lining

(API RP 652)

Visual Inspection No Lining

Ultrasonic Thickness Gauge Thick film lining (thickness ≥ 20mils=0.51mm)

Coating Thickness Gauge Thin film lining (thickness < 20mils=0.51mm)

Holiday tester Epoxy lining

GRE lining

Installation date of liner

Warranty time of liner

Found:

Holes Blisters Bulges

Cracking Mech. Damage other openings

Comments: The liner is in a good condition, and no limitations for continued service have been observed.

Unknown

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.4 Bottom Plate Condition

(API 653, Section 4 - Suitability for Service Section 4.4, page 4-11)

TBIT Inspection (MFL) Visual Inspection

Internal corrosion External corrosion Heavy pitting

Light pitting Heavy Scale Light scale

General thinning Tack welds present Lamination

Comments: The bottom has been inspected by means of an MFL/EC scan (ROSEN TBIT). In total, zero

(0) metal loss indications have been recorded in the bottom of the tank, exceeding the reporting threshold of 20%t metal loss. Assessment has shown that the repair threshold is 52%t metal loss for the bottom plates and 39%t metal loss for the annular plates, this means that the tank bottom is in compliance with API 653 at the time of inspection. The liner is in a good condition, and no limitations for continued service have been observed. Taking the thin film liner and the leak detection system into account, no repairs are required for a next service period of 5 years. Refer to Appendix A.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.5 Bottom Plate Condition Outside Tank

(API 653, Section 4.4.5.7, page 4-14)

Visual Inspection Ultrasonic Thickness Gauge

External corrosion Coating failure

Bottom-to-foundation seal damaged Projection has a welded on rain skirt

Thinning

a. The bottom projection has a drip ring installed to prevent rain water penetrating underneath the tank bottom.

b. Minor coating damage observed to the external bottom projection, only the top layer is affected.

Recommended Repairs: – Repairs recommended but not required to return the facility to service:

a) None.

b) Remove loose coating and surface corrosion to the external tank bottom / shell / roof including all appurtenances and re-apply protective coating by means of localized coating repair.(~ 15m2).

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.6 Condition of Bottom Welds

(API 653, Section 4.4.2)

Visual Inspection Vacuum Box test Eddy Current Magnetic Particle Liquid Penetrant

Corrosion Undercutting Cracks

Arc strikes Geometrical imperfections Slag remains under coating

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.6 Condition of Bottom Welds Continued

(API 653, Section 4.4.2)

a) In agreement with the ECC representative it has been agreed, that no magnetic particle inspection (MPI) was performed on the corner weld and the sump weld, due to the applied liner on these welds. The welds have been visually inspected with the liner still applied. Generally the welds appear to be in a good condition.

b) Undercut / slag is present and observed scattered over the entire circumference of the bottom-to-shell weld of the tank. The on-site ECC representative has been made aware of this.

Recommended Repairs: – Repairs recommended but not required to return the facility to service:

a) None.

b) It is recommended to remove the undercut / slag by means of grinding and perform MPI and perform weld profiling measurements afterwards to assure no cracks are present in the area and the weld profile meets the requirements of API 650 section 5.1.5.7t around the circumference of the tank.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.7 Bottom Plate Settlement

(API 653, Annex B)

Visual Inspection Laser Evaluation

Edge settlement Depression

Differential Settlement Survey Voids under bottom

Magnetic Particle Bulges

Liquid Penetrant Areas with minor drainage problems

Uneven settlement of the shell Cone down bottom

Cone up bottom

Comments: A laser survey has been performed to measure the bottom slope and edge settlement. All measurements are within API 653 rejection criteria.

Recommendations: None.

5.8 Bottom Sump

(API 653, Annex C, C.2.3)

Magnetic Particle Liquid Penetrant

Hammer Test

Internal corrosion External corrosion Heavy pitting

Light pitting Heavy Scale Light scale

General thinning Dirt and debris

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.8 Bottom Sump Continued

(API 653, Annex C, C.2.3)

Comments: The sump is covered with a lining, which is in good condition. UT spot measurements did not reveal wall thinning of the bottom sump.

Recommendations: None.

5.9 Bottom Attachments

(API 653, Annex C)

Hammer Test Magnetic Particle Inspection

Vacuum box Inspection

Check columns for corrosion up to 6 feet (1.8 m)

Bearing pads under fixed roof column bases

Restraining clips welded to bearing pads and not to column bases

Reinforcing pads under all bottom attached brackets, supports and clips

Welded attachments/reinforcing pads not in the critical zone

Attachments/reinforcing pads full seal welded

If pipe columns are present, perform random UT

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.9 Bottom Attachments Continued

(API 653, Annex C)

a) The internal piping supports are equipped with bearing pads.

b) Not at all bearing pads the minimum weld spacing requirements were taken in consideration.

Recommended Repairs: – Repairs recommended but not required to return the facility to service:

a) None.

b) Accept deviation from design code or replace none compliant bearing pads for meeting the requirements of API 650 / 653.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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5.10 Cathodic Protection of Tank(bottom)

(API RP 651, API RP 575, API 653 Section 4.4.3)

a) The tank has 4 earth cables ø8.0mm connected, unknown when the last annual resistance check has been performed.

b) The tank bottom is not equipped with a cathodic protection system.

Mandatory Repairs Group 1: – Required repairs to return the facility to service:

The following item below is not “directly” a structural integrity related repair but a repair / action to allow safe operation of the tank; taking in consideration that the tank will be used to store JP-8 (F-34).

a) Perform annual resistance checks of the Earthing. The total resistance from the tank to earth potential should not exceed approximately 25 Ohms as per API 575 3rd edition section 8.2.5., also see API 545.

Future Recommended Repairs: – Repairs that can be performed at the next inspection.

b) After the next off-stream inspection perform a corrosion assessment and remaining life calculation for the bottom. If severe corrosion is found at the next inspection is should be considered to install a Cathodic Protection System.

e7ppebmp Cross-Out e7ppebmp Line e7ppebmp

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6 SHELL REPORT

6.1 Shell Construction

(API 650, Section 5 - Design)

Butt Welded Lap Welded Riveted

The shell is constructed out of eight (8) butt welded steel plates. UT spot measurements did not reveal any general wall thinning.

Assessment has shown that the shell is strong enough to withstand the liquid load of the stored the product (and during hydro test) when the tank is completely filled (spec. gravity product: 0.84, joint efficiency factor: 1.0).

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.2 Shell Exterior Condition

(API 653, Section 4, Suitability for Service)

Visual Inspection Pit Gauge

Ultrasonic Thickness Gauge Sweep board

Corrosion Pitting Mechanical Damage

Peaking Banding Settlement

Comments: The shell is coated externally, coating is in good condition.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.3 Shell Interior Condition and Liner

(API 653, Section 4, Suitability for Service)

Visual Inspection Pit Gauge

Ultrasonic Thickness Gauge Sweep board

Grooving damage (floating roofs)

a) The shell is coated internally.

b) The coating is in a good condition except at the high and high-level openings, localized coating damage with starting surface corrosion has been observed from the tank floor.

Recommended Repairs: – Repairs recommended but not required to return the facility to service.

a) None.

b) Remove loose coating and surface corrosion to the external as well internal tank bottom / shell / roof including all appurtenances and re-apply protective coating by means of localized coating repair.(~ 15m2).

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.4 Wind Girders, Shell Stiffeners and Curb Angle

(API 653, Section 4, Suitability for Service, section 4.3.7, page 4-10)

Pit Gauge

Coating damage

Comments: No anomalies have been observed to the curb angle. Assessment has shown that the tank does not require intermediate wind stiffeners.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.5 Shell Appurtenances

(API 653, Section 4, Suitability for Service, Section 4.3.9, page 4-10)

a) Shell appurtenances attached to the shell are in good condition. UT spot measurements did not reveal any general thinning.

b) The davit of the man-way cover is not greased.

c) Localized minor coating failure has been observed to the nozzle neck, flanges and reinforcing plates of the manholes. The rust level has been estimated to be Ri2 according to ISO 4628-3, which is described as “no anomaly”.

d) Were reinforcement plates have been applied they are equipped with tell-tale holes of ø 6.0mm, however the reinforcement plate of the both man ways or constructed out of two segments, it is unknown if the butt weld connecting both segments is a full penetration weld and has fused with the original shell plate. The upper segment does not have a tell-tale hole.

Recommended Repairs: – Repairs recommended but not required to return the facility to service

b) Grease the Davits of the man-way’s.

c) Remove loose coating and surface corrosion to the external as well internal tank bottom / shell / roof including all appurtenances and re-apply protective coating by means of localized coating repair.(~ 15m2).

d) Install one telltale hole in each upper segment of the two reinforcement plates of the man-ways on the tank shell.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.6 Foundation / LDS

(API 653, Annex B, API RP 575, Section 7.2.3)

Visual Inspection Laser Elevation Survey

Concrete ring beam Compacted sand pad

Concrete Slab Concrete piled ring beam

Settlement Washed out areas Cracking

Spalling Grade against tank Vegetation

Exposed reinforcing bars Standing water against tank

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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6.6 Foundation / LDS Continued

(API 653, Annex B, API RP 575, Section 7.2.3)

The tank is resting and a concrete ring beam and has an Under Tank Leak Detection installed.

The bund floor of the secondary containment area is constructed out of concrete. As per received design drawing there is no liner installed in the secondary containment area.

The concrete wall 1.6m high and floor of the secondary containment area are cracked at several locations and are therefore not considered impermeable. Were the import and export piping penetrate the bund wall there is no jacket pipe present and also no link-seal. Light vegetation was noticed within the secondary containment area.

Mandatory Repairs Group 2 – Repairs that can be performed while the facility is in service.

The following items below are not directly structural integrity related repairs but are repairs / actions to allow safe operation of the tank; taking in consideration that the tank will be used to store JP-8 (F-34).

a) Perform repairs to the bund wall and floor of the secondary containment area, since in its current condition it is not deemed impermeable.

b) Consider to apply a jacket sleeve with the use of a link-seal at bund wall penetrations.

c) Remove vegetation from the secondary containment area.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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7 FIXED ROOF REPORT

7.1 Fixed Roof Type

(API RP 575, Section 4)

Cone Roof Dome Roof

Membrane Lattice structure Beam (Rafter) structure

Column support Self supporting

Maximum spacing of structure element at shell

The roof structure has been visually inspected from the ground floor. No distortion or damaged members of the roof was observed. Taking into account that the roof is internally coated and no corrosion has been observed form the roof plates. The inspector does not see the necessity of further detailed investigation of the roof structure.

Recommendations:

None.

1.875m

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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7.2 Fixed Roof Plate Condition

(API 653, Section 4 Suitability for Service, API 650 Annex C and H)

Hammer Test Pit Gauge

Pitting Drainage Corrosion Leakages

Coating failure Lap design Holes Depressions

a) UT spot measurements did not reveal wall thinning of the roof deck and appurtenances plates. During the inspection it has been observed that the roof deck plates are constructed in such way that condense water may entrap in the crevice of the overlap to the underside of the tank roof.

b) Minor localized coating failure and starting corrosion was noted on the roof deck and appurtenances.

The Rust level has been estimated to be Ri2 according to ISO 4628-3, which is described as “no anomaly”.

b) Remove loose coating and surface corrosion to the external as well internal tank bottom / shell / roof including all appurtenances and re-apply protective coating by means of localized coating repair.(~ 15m2).

Future Recommended Repairs – Repairs that can be performed at the next inspection.

a) Perform regular (e.g. once every year) UT inspection of the roof deck plates at the “lap” to determine if crevice corrosion is occurring at the “lap” area.

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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7.3 Fixed Roof Supports

(API 653, Section 4, Suitability for Service, API 650, Annex C and H)

Visual Inspection Hammer Test

Ultrasonic Thickness Gauge Pit Gauge

Magnetic Particle Liquid penetrant

Corrosion Thinning Coating failure

Holes Cracking Tears in guide pin

Column pad Rafter clips Loose or twisted rafters

Comments: Not Present.

7.4 Fixed Roof Appurtenances

Ultrasonic Thickness Gauge Pit Gauge

Winch jockey Sample hatch Rim vent

Gauge stilling well Manhole Blind Nozzle

Free vent Circulation Vent

Found:

Thinning Pitting Holes

Corrosion Coating failure Leakage

Telltale Hole Weld Spacing Rotating parts

Date of Inspection: 27 / 28 September 2017 Revision No.: 0

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