Attachment H - MCA - FAC 33-57- External Final -FY20.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service Inspection Report

McGuire Air National Guard, New Jersey Facility 33-57

Tank 1

US Army Corps of Engineers Center of Expertise for Petroleum, Oils and Lubricants

USACE POL-MCX

25 January 2021

API 653 In-Service Inspection Report McGuire ANG, New Jersey

Table of Contents

ACRONYMS AND ABBREVIATIONS

EXECUTIVE SUMMARY AND SUITABILITY FOR CONTINUED SERVICE

INSPECTION DATE

STATE REGULATIONS

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES

GENERAL TANK INFORMATION

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

3. Previous Inspection and Repairs

4. Future Projects

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Tank Foundation

3. Tank Shell

4. Tank Appurtenances

5. Tank Coating

6. Tank Piping System

7. Fire Protection System

8. Secondary Containment

C. FINDINGS AND RECOMMENDATIONS

1. MANDATORY REPAIRS per API 653, NFPA, or CFRs

2. SHORT TERM RECOMMENDATIONS

APPENDIX ‘A’: ENGINEERING CALCULATIONS AND DRAWINGS

SHELL SETTLEMENT SURVEY

SHELL THICKNESS CALCULATIONS

SHELL, NOZZLE, AND ROOF UT MEASUREMENTS

SHELL AND ROOF LAYOUT DRAWINGS

OSHA ACCESS STRUCTURE REPORT

APPENDIX ‘B’: SHELL ROUNDNESS AND PLUMBNESS

APPENDIX ‘C’: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX ‘D’: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

AFFF Aqueous Film Forming Foam

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

ATG Automatic Tank Gauge

BBL Barrel

CC Carbon Steel

CFR Code of Federal Regulations

CP Cathodic Protection

CS Carbon Steel

DFT Dry Film Thickness

FAC Facility

HLA High Level Alarm

HLCS High Level Control Shutoff

HHLA High-High Level Alarm

LLA Low Level Alarm

LLLA Low-Low Level Alarm

MFL Magnetic Flux Leakage

MT Magnetic Particle Testing

NA Not Applicable

NACE National Association of Corrosion Engineers

NDT Non-Destructive Testing

NFPA National Fire Protection Association

PSI Pounds per Square Inch

PT Penetrant Testing

PTFE Polytetrafluoroethylene (e.g., TEFLON)

P/V Pressure/Vacuum

PST Product Saver Tank

SS Stainless-steel

TRV Thermal Relief Valve

UFC Unified Facilities Criteria

UFGS Unified Facilities Guide Specifications

UT Ultrasonic Testing

WDO Water Draw-off

EXECUTIVE SUMMARY AND SUITABILITY FOR CONTINUED SERVICE

Austin Brockenbrough & Associates, LLC (Brockenbrough) was retained by Omaha District USACE under Contract No. W9128F-17-D-0017 Delivery Order W9128F20F0261 to perform SPCC Mandated AST Inspections at various locations. As required by this task, Brockenbrough executed a tank inspection site visit to The New Jersey Air National Guard facility located on Joint Base McGuire-Dix-Lakehurst, New Jersey. An API 653 In-service (visual external) Inspection was conducted for Facility No. 33-57, on November 4, 2020. This inspection was performed in accordance with API Standard 653, “Tank Inspection, Repair, Alteration, and Reconstruction,” and the referenced contract. The inspection included a tank foundation settlement evaluation and UT inspection of the shell and roof.

In addition, the shell was evaluated for roundness and plumbness. All observations made during this in-service (visual external) inspection were made from the exterior of the tank.

Facility 33-57 is a 31-foot diameter by 41-foot 3-inch tall, single wall, vertical, field-erected tank with a nominal storage capacity of 5,000 barrels of Jet A (F-24). The tank erector’s nameplate indicates the tank was erected by Fisher Tank Company in accordance with API 653, 9th Edition, in 1994. The tank has a Petrex aluminum internal floating pan. Secondary containment consists of an FML cover concrete dike walls and basin. Details of tank construction and appurtenances are included in the Tank Information Table at the end of this Section.

This tank was found to be in generally fair condition, with no mandatory repairs noted, and suitable for continued service. However, the CP issues appear to be more complex than usual, a thorough examination of the cathodic protection (CP) system and other corrosion prevention measures should also be performed by a Certified Cathodic Protection Engineer at or before the next inspection is performed. It should be noted that the recommended internal inspection schedule is moved up from that recommended in the last internal inspection report, due to irregularities outlined in Paragraph A.4 of this report.

Additional noted deficiencies are discussed in more detail in Section ‘C’ and should be addressed in a timely manner. Photographs of the tank are included in Appendix ‘D’.

New Jersey aboveground storage tank regulations require in-service and out-of-service inspections to be performed at intervals in accordance with API 653. The next API In-service (external) inspection of Tank Facility 33-57 should be performed by November 2025. Ultrasonic thickness inspection of the shell should be performed by November 2035. The next API 653 Out-of-service (internal) Inspection should be performed by June 2024. The inspection should include temporary removal of the internal stainless-steel low suction and main suction piping, which current block access for inspection of the sump. The presence of stainless-steel and water in the sump could result in accelerated galvanic corrosion under any cracks or holidays in the sump coating. The inspection should also include an examination of the tank bottom by magnetic flux leakage (MFL or MFE) technology and a thorough code compliance evaluation.

INSPECTION DATE

API 653 In-Service (External) Inspection Date: 4 November 2020

Equipment Used:

Shell Roundness and Settlement Surveys Manufacturer: Topcon Model Number: QS X-Trac 8 Robotic/Reflectorless Total Station Calibration Method: Field Calibration: Inverse Vertical Collimation Factory Calibration: Annual Horizontal

Shell Roundness Survey Manufacturer: Topcon Model Number: FC-5000 Field Data Collector Calibration Method: None needed

Shell Settlement Survey Manufacturer: Topcon Model Number: FC-2500 Field Data Collector Calibration Method: None needed

Shell Ultrasonic Thickness Inspection

Manufacturer: NDT Systems Model Number: Nova TG110-DL with 560P (Thru-paint) Probe Calibration Method: Yearly Shop Calibration and Field Calibration (step block) NDT Technician (s): Mike O’Connor

Inspector(s): Mike O’Connor

STATE REGULATIONS

State Regulation for API In-Service Tank Inspections November 2025 State Regulation for API Out-of-Service Tank Inspections June 2024

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: 3 June 2009 API In-Service (External) Inspection Date: NA

RECOMMENDED FUTURE INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: June 2024 API Ultrasonic Thickness Inspection of Shell Date: November 2035 API In-Service (External) Inspection Date: November 2025

Mike O’Connor Mechanical Designer API 653 Inspector No. 6230

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner New Jersey Air National Guard Location Joint Base McGuire-Dix-Lakehurst Facility Number 33-57 Tank Number Tank 1 State / Country New Jersey / U.S.A.

City Wrightstown Inspection Date 4 November 2020 Tank Manufacturer Fisher Tank Company Design Standard API 650 – 9th Edition (per nameplate) Date of Construction 1994 (per nameplate) Tank Contents Jet A (F-24) Tank Serial Number 5225 Tank Diameter 31’-0” Shell Height 41’-3” Overflow Height 37’-6” Tank Capacity 5,000 BBL nominal (per nameplate), 4,460 BBL (LLA to HLA).

Foundation 14” tall concrete ring wall.

Construction and Material Bottom

Lap-welded 5/16” thick carbon steel plate with 5/16” thick butt welded annular ring (per 2009 inspection report).

Shell Five courses of 1/4" thick butt-welded carbon steel plate.

Floating Roof Petrex aluminum internal floating pan.

Fixed Roof Lap welded steel cone roof.

Cathodic Protection Impressed Current and/or corrosion inhibitor.

Interior Coating System Epoxy 100% (assumed)

Exterior Coating System Epoxy/epoxy/polyurethane (assumed).

Level Gauging ITT Barton ATG and water probe, manual gauging well, Shand and Jurs autogauge (mechanical tape level gauge).

Overfill Protection Independent high and high-high level alarms, ATG (redundant) alarms, hydraulic operated high level control valve.

Piping

Receipt 8” Welded carbon steel Issue 10” Welded stainless-steel Low Suction 4” Welded stainless-steel Water Draw-off 3/4” Welded stainless-steel

Level Alarms Shell mounted (independent) high, high-high, and low level alarms; ATG (redundant) Alarms.

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

This project will perform API 653 and STI SP001 inspections of various tanks at facilities throughout the United States. The specific inspection performed is based on available information on the tank type, product being stored, and recommendations from previous inspection reports (if available). Additional consideration is given to federal, state, and local regulations, as well as applicable military criteria and general industry standards.

For this Task Order, Brockenbrough performed Inspection of Facilities 33-57 and 33-58 located at the New Jersey Air National Guard facility, on Joint Base McGuire-Dix-Lakehurst, New Jersey. For Facility 33-57, an API 653 In-service (external) Tank Inspection was performed on 4 November 2020. The inspection included shell settlement, shell roundness and plumbness surveys, and a shell UT inspection.

2. Site Information

Joint Base McGuire-Dix-Lakehurst (JB MDL) is located 18 miles (29 km) southeast of Trenton, New Jersey in the counties of Burlington and Ocean, and includes portions of eight municipalities: the borough of Wrightstown and the townships of New Hanover, North Hanover, Pemberton, Springfield Jackson, Manchester, and Plumsted. The 42,000-contiguous acres of JB MDL are home to more than 80 mission partners and 40 mission commanders providing a wide range of combat capability. Spanning more than 20 miles from east to west, the facility is an amalgamation of the United States Air Force's McGuire Air Force Base, the United States Army's Fort Dix and the United States Navy's Naval Air Engineering Station Lakehurst, which were merged on 1 October 2009 in accordance with congressional legislation implementing the recommendations of the 2005 Base Realignment and Closure Commission.

The 87th Air Base Wing provides installation management support for 3,933 facilities with an approximate value of $9.3 billion in physical infrastructure. JB MDL is the only tri-service base in the United States Department of Defense and includes units from all five armed forces branches. More than 44,000 airmen, soldiers, sailors, marines, Coast Guardsmen, civilians, and their family members live and work on and around the Base.

3. Previous Inspection and Repairs

The previous API 653 Out-of-service inspection report recommended the next API 653 Out-of-service inspection for Tank Facility 33-57 to be performed by June 2029 with the condition that the cathodic protection system would be maintained. However, Facility personnel indicated the Cathodic protection system for the tank has not worked in many years and corrosion inhibitor was injected under the tank bottom. In addition, the previous out-of-service inspection reports did not consider the effect of anodic corrosion that the stainless-steel internal piping could have on the interiors of the tank bottoms.

4. Accelerated Inspection Schedule

It should be noted that the recommended internal inspection schedule is moved up from that recommended in the last internal inspection report, due to irregularities in the CP system, the presence of stainless-steel in the tank bottom sump, lack of access to thoroughly examine the sump during the previous internal inspection, coating failures on the tank bottom that were noted during the previous report, and lack of records indicating the tank bottom coating failures have been addressed. The next API 653 Out-of-service (internal) Inspection should be performed by June 2024.

https://en.wikipedia.org/wiki/Trenton,_New_Jersey https://en.wikipedia.org/wiki/Trenton,_New_Jersey https://en.wikipedia.org/wiki/List_of_counties_in_New_Jersey https://en.wikipedia.org/wiki/Burlington_County,_New_Jersey https://en.wikipedia.org/wiki/Ocean_County,_New_Jersey https://en.wikipedia.org/wiki/Wrightstown,_New_Jersey https://en.wikipedia.org/wiki/New_Hanover_Township,_New_Jersey https://en.wikipedia.org/wiki/North_Hanover_Township,_New_Jersey https://en.wikipedia.org/wiki/Pemberton_Township,_New_Jersey https://en.wikipedia.org/wiki/Springfield_Township,_Burlington_County,_New_Jersey https://en.wikipedia.org/wiki/Jackson_Township,_New_Jersey https://en.wikipedia.org/wiki/Manchester_Township,_New_Jersey https://en.wikipedia.org/wiki/Plumsted_Township,_New_Jersey https://en.wikipedia.org/wiki/United_States_Air_Force https://en.wikipedia.org/wiki/United_States_Air_Force https://en.wikipedia.org/wiki/McGuire_Air_Force_Base https://en.wikipedia.org/wiki/United_States_Army https://en.wikipedia.org/wiki/Fort_Dix https://en.wikipedia.org/wiki/United_States_Navy https://en.wikipedia.org/wiki/Naval_Air_Engineering_Station_Lakehurst https://en.wikipedia.org/wiki/Naval_Air_Engineering_Station_Lakehurst https://en.wikipedia.org/wiki/Base_Realignment_and_Closure_Commission https://en.wikipedia.org/wiki/Base_Realignment_and_Closure_Commission https://en.wikipedia.org/wiki/87th_Air_Base_Wing https://en.wikipedia.org/wiki/United_States_Department_of_Defense

5. Previous Inspection and Repairs

A 2010 repair completion report indicates the repairs that were performed following the 2009 out-of-service inspection included installing the 2-inch water probe well under the center vent and installing the manual gauging well and floating plug retriever. The coupling in the neck of the roof center vent for installing a future water probe was likely also installed at that time.

6. Future Projects Facility personnel report there are currently no projects scheduled for execution in the future that affect the operation of the tank.

B. TANK INSPECTION COMMENTS

1. Tank Construction Tank Facility 33-57 is an aboveground, vertical, storage tank, with a cone roof and aluminum internal floating pan. The tank is 31 feet in diameter and 41 feet 3 inches tall and has a nominal capacity of 5,000 BBLs (per the data plate). The capacity of the tank from the bottom of the shell to the overflow is calculated to be approximately 5,040 BBLs. The capacity of the tank from the low level alarm to the high level alarm is calculated to be approximately 4,460 BBLs. The tank manufacturer’s nameplate indicates the tank was constructed to API 650 - 9th Edition in 1994.

2. Tank Foundation The perimeter of the bottom rests on a 14-inch tall concrete ringwall, with two leak detection tell-tales.

The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. No issues with the foundation were noted. A shell settlement survey was performed during the inspection in accordance with Appendix ‘B’ of API Standard 653. The shell settlement evaluation indicates the settlement of the bottom of the shell and perimeter of the tank bottom is acceptable.

3. Tank Shell The vertical and cylindrical shell consists of five butt welded courses. The ultrasonic thickness measurements of the shell and calculations included in Appendix ‘A’ indicate the shell has more than 30 years of remaining life. API 653 recommends ultrasonic thickness measurements of the shell be taken at least every 15 years. The exterior of the shell was visually inspected and evaluated for plumbness, roundness, peaking and banding. Little peaking and banding of the butt-welded shell seams were observed. The peaking-and-banding appeared to be within limits allowed by API 650.

There is no definitive criterion for determining tolerance of plumbness for an existing tank in API 653.

API 650, paragraph 7.5.2 allows a maximum out-of-plumb of the top of a new tank shell relative to the tank bottom of 1/200 the height of the shell, a difference of 2 1/2 inches for this 41-foot 3-inch tall tank. The maximum measured out-of-plumbness was 1/1/2 inches away the tank center measured on the west side. The out-of-plumbness of the shell is within that allowed by API 650 for a new tank.

There is no definitive criterion for determining tolerance of roundness for an existing tank in API 653.

The shape of the shell appears to exceed the allowable API 650 tolerance of plus or minus 1-inch of a new tank shell radius. Based on the circumference of the shell measured near the bottom, the outside radius of the shell should be 15 feet 6 inches. However, the measured radii of the shell vary one foot above the bottom from 15 feet 4 5/16 inches in the west to 15 feet 6 5/8 inches in the southwest. Also, the measured radii of the shell vary near the top from 15 feet 5 5/8 inches in the northeast and north west to 15 feet 7 3/8 inches in the north-northeast. In addition, a slight bulge was observed on the southwest side of the shell where the radius was measured to be approximately 15 feet 7 1/2 inches.

The radius directly below that location one foot above the tank bottom was measured to be only approximately 15 feet 5 7/8 inches. As the out-of-roundness does not appear to be a detriment to the structural integrity of the tank, no action is required or recommended at this time.

4. Tank Appurtenances

a. Cone Roof

The tank roof is a lap-welded cone roof, constructed out of steel plate. The roof is supported by eight rafters spaced approximately 12 feet apart at the perimeter. API 650 requires the rafters to be spaced no further apart than seven feet at the perimeter. However, only minor signs of water ponding near the perimeter of the roof as a result of the extreme rafter spacing were noted. There is coating failure on the underside of the roof plate. Access to the internal ladder is gained through a 36-inch round roof hatch. The neck of the round hatch does not provide 30 inches of clearance on the climbing side of the ladder as required by OSHA.

b. Gauging

The tank’s ITT Barton/Cameron ATG is installed through a 10-inch stainless-steel stilling well. The 10-inch stilling well is only partially slotted. The 8-inch aluminum manual gauge well, which was installed in 2010, is fitted with a floating plug retriever. The tank also has a Shand and Jurs autogauge. Due to the autogauge being installed by attaching the autogauge tape directly to the internal floating pan and contrary to manufacturer’s instructions to install it on a float or on a weight resting on top of the pan, the autogauge is damaged and inoperable. In addition, the autogauge has not been maintained and the reading window is dirty and unreadable.

c. Level Alarms The tank has shell mounted (independent) high, high-high, and low level alarms. The tank also has redundant ATG alarms. The low level alarm is set approximately at the low leg level of the internal floating pan. The facility normally operates with the pan legs set in the high level. There are no independent alarms at 6 minutes and 1 minute before the pan sets down on low legs as prescribed by the current UFC 3-460-01.

d. Stairs and Platforms The tank’s steel cone roof is accessible by a circumferential stairway mounted on the shell of the tank. The circumferential stairway step rise is generally 9 inches continuously from the lowest step to the top landing. The lowest step is only 8 inches above the concrete landing. The width of the stair steps is generally 32 inches. The measured height of the stairway handrail is 32 inches. The clearance between the level control float chamber and the stairway posts ad handrail is only 14 inches. The clearance between the high and high-high level alarm sensor chambers and the stairway handrail is only 19 1/2 inches. OSHA requires a stairway step with a least 22 inches between vertical barriers.

e. Grounding and Bonding The tank’s four grounding cables are bolted to lugs welded to the anchor chairs, rather than welded, but appear to be in good condition.

5. Tank Coating The tank’s coatings were evaluated for deterioration. The exterior of the shell shows little sign of significant deterioration. However, there is isolated coating damage on the shell from a prior adhesion test, general coating failure and corrosion on the exterior of the roof, stairway handrails and posts, coating failure on the level alarm and level control float chambers. The mid-rail chains above the four roof perimeter vent/inspection hatches are corroded and lying on the vent hoods resulting in staining and coating failure on the hoods. There is coating failure and corrosion on the topsides and undersides of the roof center vent flange and perimeter vent/inspection hatch hoods. The conduit support channel laying on the roof are not seal welded to the roof and are corroded. There are bird droppings on the roof and appurtenances, which could accelerate deterioration. There is also an 18-inch blind flange lying on the roof of the tank, which promotes corrosion.

6. Tank Piping System Facility 33-57 is a hydrant system tank. Per Facility personnel, the tank does not receive fuel from the bulk fuel facility on-Base, but primarily from a separate commercial pipeline with backup receipt from a truck off-load station located adjacent to the pumphouse. Fuel is issued to the hydrant system, and various truck fillstands. The shell nozzles and internal piping are stainless-steel. The receipt piping is aboveground carbon steel. The issue piping is aboveground stainless-steel. There appears to be adequate thermal relief throughout the piping system. However, the issue piping thermal relief valve is set at 275 psi, which may be higher than necessary. In addition, the thermal relief piping does not include testing tees. There are four sight flow indicators on receipt and issue TRV drain piping. The washers and jam nuts on top of the stainless-steel TRVs are corroded carbon steel. While the TRVs are stainless-steel. The receipt TRV piping is a mixture of stainless-steel and carbon steel. The stainless-steel receipt TRV drain piping is welded to a carbon steel coupling, which is also welded to a stainless-steel branch connection on the neck of the stainless-steel issue nozzle. A 3/4-inch branch connection on the neck of the low suction terminates in a threaded (NPT) carbon steel cap. The 3/4-inch stainless-steel piping of the product saver tank is threaded. The material of the stainless-steel level control valve cover and its bolting does not match the rest of the valve and is corroded. There is algae growth on underside of piping. The 3/4-inch drain piping from the product saver tank to the 2-inch PST drainpipe header (to pumphouse filter/separator #1 effluent) includes a sight flow indicator.

7. Fire Protection System There is one AFFF chamber on the tank and two fire hydrants in the vicinity in addition to foam cannons. While AFFF chambers were required for JP-4 (Flash point -20 F., Reid Vapor Pressure 3.0 psi), the chambers are not required for Jet A or JP-8 (Flash point 100 F., Reid Vapor Pressure 0.05 psi), and are not standard for this type of tank, but may have been required by the Local Authority Having Jurisdiction (ANG) based on their experience with the more volatile and unstable JP-4 that was used during the mid-twentieth century. The military has fully transitioned to JP-8 and Jet A, which has been demonstrated to be safe to store and handle without AFFF protection for nearly three decades. Facility personnel indicated that the limited resources of the local fire department are expended regularly to inspect, test, and maintain the foam chambers and cannons regularly.

8. Secondary Containment Secondary containment consists of an FML covered concrete dike walls and basin. The secondary containment was evaluated during the inspection. The containment is of sufficient size to contain a total tank loss plus an additional nine inches of freeboard. Some additional secondary containment capacity may be provided by the swale. The tank’s four ground cables penetrate the secondary containment FML through unsealed plastic pipe. Four of twelve dike basin FML (secondary containment) penetrations for the 2-inch PST drainpipe header supports have failed.

C. FINDINGS AND RECOMMENDATIONS

Tank Facility 33-57 was found to be in generally fair condition. The tank is fully serviceable, with no mandatory deficiencies that would require immediate removal of the tank from service. However, there were a few items observed that could be addressed to reduce long term maintenance, improve operability, and more clearly comply with federal, state, and local regulations or military criteria.

1. MANDATORY REPAIRS per API 653, NFPA, or CFRs Mandatory repairs represent items that require immediate attention in order to prevent imminent risk to system operators, equipment, or the adjacent environment. The tank would have to be taken out-of-service to complete these repairs. No Mandatory Repairs are required to be performed.

2. SHORT-TERM RECOMMENDATIONS

REQUIRED REPAIRS to Fully Comply with API 653, UFC 3-460-01, or AW 78-24-27 Standards Short- Term Repairs that directly relate to the long-term preservation of the asset. Short-term repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment. These items may be required by Federal, State, and Local Codes or by Military Criteria.

a. Perform Thorough Investigation of the Cathodic Protection (CP) System OBSERVATION: The future inspection recommendations included in the July 2009 out-of-service inspection report were contingent on the CP system remaining operable. Facility personnel indicated the CP system is inoperable due to “depleted anodes” and that corrosion inhibitor was injected under the tank bottom. However, the CP system appeared to be operable during this inspection. There was however no power to the cathodic protection system of the adjacent tank.

We have observed that it is often the case that little current flows through dry sand from new CP anodes installed under elevated tank bottoms, which could be misinterpreted as “depleted anodes,” but that depletion of impressed current CP anodes installed in such dry sand is rare.

REFERENCE: Guidance for new construction, provided in UFC 3-460-and UFC 3-460-01, includes cathodic protection for aboveground storage tanks bottoms.

RECOMMENDATION: As the CP issues appear to be more complex than usual, perform a thorough examination of the cathodic protection system and other corrosion prevention using the services of a Certified Cathodic Protection Engineer.

b. Demolish or Reinstall and Recalibrate Autogauge OBSERVATION: Due to the Shand and Jurs autogauge being installed by attaching the autogauge tape directly to the internal floating pan and contrary to manufacturer’s instructions to install it on a float or on a weight resting on top of the pan, the autogauge is damaged and inoperable. In addition, the autogauge has not been maintained and the reading window is dirty and unreadable.

The screws on the autogauge tape roller cover on the roof are corroded.

REFERENCE: Guidance for new construction, provided in UFC 3-460-01, Table 8-1, Item o, and DoD Standard Design AW 78-24-27 (2015), includes a mechanical tape level gauge (autogauge).

Manufacturers of mechanical tape level gauges (Varec and Shand and Jurs) recommend attaching the tape to a float in a floating pan penetration well or to a weight resting on top of the pan, but not directly to the pan to avoid damage to the tape or gauge head in the event the pan does not descend smoothly with the fuel, which is a consistent problem with smaller tanks.

RECOMMENDATION: Demolish the autogauge or reinstall the autogauge by attaching the tape to a weight resting on top of the pan in accordance with manufacturer’s recommendations, calibrate the autogauge to agree with the ATG and manual gauging, and clean and service the autogauge head.

Replace the screws on the autogauge tape guide roller cover on the roof.

c. Modify Stairway OBSERVATION: The rise of the circumferential stairway is approximately 9 inches. However, the rise of the bottom step above the concrete landing on the dike basin is only 8 inches. The clearance between the level control float chamber and the stairway posts ad handrail is only 14 inches. The clearance between the high and high-high level alarm sensor chambers and the stairway handrail is only 19 1/2 inches.

REFERENCE: OSHA regulation 29 CFR 1910.25 (c) (4) (December 2017) requires clearance at a stairway of at least 22 inches. The minimum width of stairs required in API 650 Table 5.18 has increased over the years, from 24 inches in 1993 to 28 inches in the latest edition. OSHA regulation 29 CFR 1910.25 (b) (3) (December 2017) requires the step rise to be uniform throughout any flight of stairs.

RECOMMENDATION: Reinstall the high and high-high level alarm chambers and the level control chamber or modify the circumferential stairway to provide at least 22 inches of horizontal clearance at the level alarms and control chambers and replace the concrete landing at the bottom of the circumferential stairway to provide a rise from the landing to the bottom stair step of approximately 9 inches.

d. Provide OSHA Compliant Internal Ladder Access Hatch OBSERVATION: The 36-inch internal ladder access manhole provides only 26 inches of clearance on the climbing side of the ladder.

REFERENCE: OSHA regulation 29 CFR 1910.23 (d) (June 2018) requires 30 inches of clearance (24 inches with a deflector plate) on the climbing side of a ladder including at access hatches. Guidance for new construction, provided in DoD design Standard AW 78-24-27, includes an OSHA compliant internal ladder access hatch.

RECOMMENDATION: Provide an OSHA compliant internal ladder access hatch.

e. Replace the Roof Perimeter Vent/Inspection Hatch Latches OBSERVATION: The roof perimeter vent/inspection hatch hood latches are misaligned, painted inoperable, and/or broken. The hoods are wired down. Maintenance and inspection activities are hampered due to the condition of the latches. Improperly secured appurtenances may result in damage to the tank and other equipment at the Base in the event of high winds.

REFERENCE: DoD AST Standard Design AW 78-24-2API 653, includes stainless-steel roof perimeter vent/inspection hatch latches. Appendix ‘C’ (Checklist for Out-of-service Inspection) item C.1.4.4 includes measuring the level of the internal floating roof (IFR) at several locations to aid in revealing any problems with the IFR. UFC 3-460-03, section 8-9.1.1 requires the facility to occasionally visually inspect the IFR for damage.

RECOMMENDATION: Replace the four roof perimeter vent inspection hatch latches with stainless-steel latches per DoD AST Standard Design AW 78-24-27.

f. Replace Exterior Coatings OBSERVATION: The exterior shell coating shows little sign of significant deterioration. However, the shell coating is believed to be the original and approximately 26 years old. In addition, there is isolated coating damage on the shell from a prior adhesion test, and there is also general coating failure and corrosion on the exterior of the roof, stairway handrails and posts, as well as coating failure on the level alarm and level control float chambers. The mid-rail chains above the four roof perimeter vent/inspection hatches are corroded and lying on the vent hoods, which has resulted in corrosion staining and coating failure on the hoods. Some of the chain hasps are inoperable. There is also coating failure and corrosion on the undersides of the hoods. There is coating failure and corrosion on the underside of the roof center vent flange. The conduit support channel laying on the roof are not seal welded to the roof and are corroded.

REFERENCE: Guidance for new construction, provided in UFC 3-460-01, paragraph 8-3.10, includes exterior coatings. DoD Standard Design AW 78-24-27 does not include mid-rail chains.

RECOMMENDATION: Eliminate or replace the mid-rail chains above the roof perimeter vent inspection hatches with stainless-steel. Ensure the mid-rail chains are not laying on top of the vent hoods. Replace the conduit support channel on the roof with conduit supports that comply with the DoD Standard Design AW 78-24-27. Replace the external tank and appurtenance coatings, including coatings under the roof vent and manhole covers and hoods. As the shell coating is believed to be approximately 26 years old and mobilization represents a significant portion of the cost of providing military coatings, replacing the external shell coatings is included in this recommendation.

3. LONG-TERM RECOMMENDATIONS

RECOMMENDED REPAIRS as Part of Regular Maintenance Long-term Repairs that directly relate to repair/upgrade of an asset to bring it up to the current standard from the standard at time of construction. Long-term Repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. Remove Soil and Vegetation OBSERVATION: There is soil, shells, seeds, bird droppings, and algae on the secondary containment basin FML. Vegetation is growing out from under the FML walkways.

REFERENCE: Guidance for maintenance of fuel storage facilities, provided in UFC 3-460-03 Section 8- 10.2.2, includes daily inspection of secondary containment for cleanliness and removal of debris and vegetation.

RECOMMENDATION: Remove the soil, shells, seeds, bird droppings, algae, other debris and vegetation from the secondary containment including from under the FML walkways.

b. Provide Plug OBSERVATION: When the water probe stilling well was provided in 2010, the contractor installed an open coupling (without a plug) in the center vent nozzle neck for future installation of the water probe. The open coupling allows birds to enter the tank.

REFERENCE: API 650 Addendum H requires vent screens with 1/2-inch openings.

RECOMMENDATION: Provide a plug for the coupling in the center vent nozzle neck.

c. Clean the Roof OBSERVATION: Bird droppings and an abandoned 18-inch flange were found on top of the tank roof.

Loose items laying on top of the roof can result in coating failure and corrosion.

REFERENCE: UFC 3-460-03, Appendix F (Monthly Tank Inspection Checklists) requires Facility personnel to inspect for evidence of corrosion. API 571 paragraph 4.3.2.3.h) reads, “bird turds can also cause accelerated corrosion and unsightly stains.” Guidance for new construction, provided in UFC 3-460-01 paragraph 8-3.10, includes coating the exterior.

RECOMMENDATION: Include pressure washing of the tank roof to remove loose debris and animal feces in the periodic maintenance checklist. Remove the abandoned piping flange from the roof.

d. Pressure Wash Piping OBSERVATION: The coated carbon steel piping in the dike area is covered with algae. There is coating failure and corrosion on the pipe supports.

REFERENCE: Guidance for construction of new fuel piping includes external coating of carbon steel piping. Guidance for maintenance of petroleum facilities, included in UFC 3-460-03 paragraph 6- 10.1, requires periodic inspection and maintenance of equipment coatings.

RECOMMENDATION: Add pressure washing the piping and equipment in the dike area to the periodic maintenance schedule. Spot repair the coatings on the pipe supports.

e. Seal FML Penetrations OBSERVATION: The tank’s four ground cables penetrate the FML through unsealed plastic pipes.

Four of twelve dike basin FML (secondary containment) penetrations for the 2-inch PST drainpipe header have failed.

REFERENCE: NFPA 30 paragraph 22.11.2.4 and 40 CFR 112.7(c)(1) require dikes to be liquid tight.

Guidance for maintenance of fuel storage facilities, provided in UFC 3-460-03 paragraph 8-10.2.2, includes daily inspection of concrete secondary containment for failed sealants.

RECOMMENDATION: Seal the ground cable penetrations through the plastic pipe FML penetrations using fuel and UV resistant sealant. Seal the dike basin FML (secondary containment) penetrations for the 2-inch PST drainpipe header supports using fuel and UV resistant sealant.

f. Replace Level Control Valve or Cover and Bolting OBSERVATION: The material of the stainless-steel level control valve cover and its bolting does not match the rest of the valve and is corroded.

REFERENCE: Guidance for construction of fuel system piping provided in UFC 3-460-01 paragraph 15-11.5 includes diaphragm control valves made of stainless-steel or internally chrome plated steel or internally nickel-plated nodular iron.

RECOMMENDATION: Replace the level control valve cover and its bolting to match the material of the stainless-steel valve body or replace the level control valve.

g. Provide Exothermic Welded Grounding Connections OBSERVATION: The tank’s grounding cables are bolted to carbon steel lugs.

REFERENCE: Guidance for new construction, provided in DoD Standard Design AW 78-24-27, includes four grounding lugs and cables, and includes exothermic welding the grounding cables to stainless-steel grounding lugs per Detail 2/ED.02.

RECOMMENDATION: Replace the four grounding lugs with stainless-steel grounding lugs.

Exothermically weld the grounding cables to the new stainless-steel lugs.

h. Demolish the AFFF Chamber, Piping, and Cannon System OBSERVATION: There are two fire hydrants within 300 feet of the tank. There is also an aqueous firefighting foam (AFFF) chamber on the top shell course. In addition, there are foam cannons stationed around the tank. The tank was built at a time when the military was transitioning away from JP-4, which was considered to be highly volatile and required AFFF protection. However, the Air Force has fully transitioned to JP-8 and Jet A, which has been demonstrated to be safe to store and handle without AFFF protection for nearly three decades. Facility personnel indicated that the limited resources of the local fire department are expended regularly to inspect, test, and maintain the foam chambers and cannons regularly.

REFERENCE: Guidance for new construction, provided in UFC 3-460-01 and NFPA 30, do not include or require AFFF for Class II liquids. Current Air National Guard standards include AFFF chambers on jet fuel storage tanks. Guidance for operation and maintenance of AFFF systems, provided in UFC 3-601-02, includes maintenance and periodic testing. NFPA 11, Chapter 12 requires periodic maintenance and testing of AFFF systems.

RECOMMENDATION: If the Air National Guard concurs, demolish the AFFF system, cannons, piping, and foam chamber on the tank, piping and supports in the dike area, and components of the AFFF system outside the dike area.

AFFF Piping

Foam Cannon

i. Modify Thermal Relief Piping OBSERVATION: The issue piping thermal relief valve is set at 275 psi, which may be higher than necessary. In addition, the thermal relief piping does not include testing tees. There are four sight flow indicators on receipt and issue TRV drain piping. The washers and jam nuts on top of the stainless-steel TRVs are corroded carbon steel. While the TRVs are stainless-steel, the receipt TRV piping is a mixture of stainless-steel and carbon steel. The stainless-steel receipt TRV drain piping is welded to a carbon steel coupling which is welded to a stainless-steel branch connection on the neck of the stainless-steel issue nozzle.

REFERENCE: DoD Standard Design AW 78-24-27 includes stainless-steel thermal relief piping and valves at storage tanks. Guidance for new construction, provided in UFC 3-460-01 paragraph 9-

3.5.1 recommends a TRV set pressure of 10 percent above pump deadhead, prohibits installing sight flow indicators on new thermal relief piping, and requires that when a stainless-steel valve is provided, all components including bonnet and adjustments be stainless-steel . Guidance for new construction, provided in UFC 3-460-01 paragraph 2-11.3.3, prohibits bonding of dissimilar metals.

RECOMMENDATION: Replace the receipt and issue thermal relief piping and valves in accordance with UFC 3-460-01 and DoD Standard Design AW 78-24-27.

CS

SS

SS

CS

CS

SFI

j. Modify the Roof Support Structure OBSERVATION: The 8 roof rafters are spaced approximately 22 1/2 degrees apart (17 feet apart at the perimeter of the roof). At this time, the tank’s steel, lap welded, cone roof shows only minor sign of water ponding around the perimeter. However, this is expected to worsen over time. There is coating failure on the underside of the roof plate.

REFERENCE: As early as 1996, API 650 required rafter spacing at the perimeter of the tank roof to be no greater than 75 inches apart. Earlier API requirements may have been more stringent. Later editions of API 650, paragraph 5.10.4.4 increased the maximum allowable spacing to 84 inches.

RECOMMENDATION: Modify the roof support structure to eliminate the water ponding and bring the roof rafter spacing into compliance with API 650.

This photo is from the 2009 internal inspection.

k. Eliminate Connections Between Dissimilar Metals OBSERVATION: Photographs in the 2009 internal inspection report help to reveal that the design of the piping system varies from the standard design in that the interior piping, product nozzles and ATG stilling well are stainless-steel. In addition, there is a 3/4-inch branch off the low suction nozzle neck, and a 3-inch branch off the low suction piping from the pumphouse. Arrows painted on the carbon steel branch piping from the pumphouse indicate the flow is into the low suction piping. The presence of stainless-steel and on the interior of the tank near the tank bottom could result in accelerated galvanic corrosion at a crack in the coating. A stainless-steel flange is welded onto the carbon steel branch piping at its connection to the stainless-steel low suction piping. In addition, there is a carbon steel check valve between the branch piping’s stainless-steel flange and the low suction stainless-steel flange. There is also a 3/4-inch branch connection on the neck of the low suction that terminates in a threaded (NPT) carbon steel cap.

REFERENCE: Guidance for new construction provided in UFC 3-460-01 paragraph 9-8. e) prohibits bonding dissimilar metals, prohibits installing threaded piping on new fuel piping, and prohibits back welding of threaded piping.

RECOMMENDATION: Replace the shell product stainless-steel nozzles and internal stainless-steel piping and supports, with carbon steel. Replace the stainless-steel ATG stilling well with full length slotted aluminum. If the branch connection from the pumphouse to the low suction piping is warranted, replace the stainless-steel flange that is currently welded to the branch piping with carbon steel. If the shell nozzles are not replaced with carbon steel, demolish the 3/4-inch threaded branch connection on the neck of the low suction.

CS

SS CS

l. Upgrade Water Draw-off System OBSERVATION: The 3/4-inch water draw-off (WDO) nozzle and internal piping to the sump are stainless-steel (SS). The presence of SS and water in the sump could result in accelerated galvanic corrosion at a crack in the coating. The WDO nozzle is fitted with a ball valve. There is no dedicate product return nozzle. However, the product saver tank (PST) drain is piped to the receipt Filter- Separator #1 inside the pumphouse. There is no electrical isolation between the SS-PST piping and the tank. The PST does not have a dedicated ground.

REFERENCE: Guidance provided in DoD Standard Design AW 78-24-27 and UFC 3-460-01 includes carbon steel (CS) internal piping and supports, dedicated 2-inch CS WDO and product return nozzles fitted with CS double block and bleed (DBB) valves, electrical isolation between the SS PST piping and the CS tank nozzle valves, and a dedicated grounding system for the PST.

RECOMMENDATION: Provide 2-inch flanged CS-WDO and return nozzles on the tank shell. Replace the SS internal WDO piping and supports with CS. Provide flanged, CS, DBB valves on the new WDO and return nozzles, and electrical isolation between the SS PST piping and the CS valves and piping valves. Provide a dedicated grounding system for the PST.

m. Eliminate Threaded Connections OBSERVATION: The 3/4-inch stainless-steel piping of the product saver tank is threaded.

REFERENCE: Guidance for new construction provided in UFC 3-460-01 paragraph 9-8. e) prohibits installing threaded piping on new fuel piping.

RECOMMENDATION: Replace the threaded PST piping connections with welded connections.

Water Draw-off

n. Eliminate Redundant and Incorrectly Placed Overflows OBSERVATION: One of the four shell overflows is over the stairs. Two of the overflows are near to over the receipt and issue nozzle valves.

REFERENCE: API 650 paragraph H.5.3.3 does not allow overflows to be located over stairways or tank nozzle isolation valves. DoD Standard Design shows only one overflow on a 5,000 BBL tank with an 8-inch receipt nozzle, and that overflow is on the side of the tank opposite the product nozzles and the stairway. API 650 paragraph H.5.2.2.1 also requires peripheral circulation vents to provide 2 square feet of net open area in any 32 feet of circumference.

RECOMMENDATION: Raise or eliminate the existing shell overflows, currently located near to over the bottom of the stairway, and tank nozzles. Verify that the remaining overflows are sufficient to handle at the rate of the maximum receipt.

o. Provide Scaffold Cable Supports OBSERVATION: There are no scaffold cable supports on the fixed roof.

REFERENCE: Guidance for the design of new storage tanks, provided in UFC 3-460-01, Table 8-1, Item ff, and DoD Standard Design AW 78-24-27, includes scaffold cable supports on the fixed roof.

RECOMMENDATION: If the industry develops means for a coating contractor to make use of scaffold cable supports on a tank with guardrails all around the perimeter of its roof, the next time interior tank coating work is performed, provide two scaffold cable supports on the fixed roof.

Overflow

Issue

Overflow

Receipt

This overflow to Remain

Receipt

Overflow

p. Demolish Abandoned Support Brackets OBSERVATION: There are 4 abandoned AFFF piping support brackets on the exterior of the shell.

Abandoned appurtenances are a source for corrosion and a drain on maintenance resources.

REFERENCE: NA.

RECOMMENDATION: Demolish the abandoned AFFF piping support brackets on the shell of the tank.

APPENDIX ‘A’: ENGINEERING CALCULATIONS AND DRAWINGS

SHELL SETTLEMENT SURVEY

Austin Brockenbrough & Associates, L.L.P. Job No. 20-056.02 Location: McGuire ANG Date: 11/19/20 Subject: Tank FAC 33-57 - Shell Settlement Evaluation By: Mike O'Connor

API 653 Appendix B Optimum cosine curve, B 2.2.4.e) Z = a + b x cos(theta + c)

Diameter (D) = 31 (ft) Number of equally spaced data points (ft)= 8 L = Arc length between measurement points (ft) = 12.17 Tank Height (H) = 41.25 (ft)

Relative elevation of lowest horizontal weld seam. (ft)

* Z U S

0 99.950 0.00 0.00 0.00 0.00 1 99.950 0.00 0.00 0.00 0.00 2 99.960 0.01 0.01 0.00 0.00 3 99.970 0.02 0.02 0.00 0.00 4 99.980 0.03 0.03 0.00 -0.01 5 99.970 0.02 0.02 0.00 0.00 6 99.960 0.01 0.01 0.00 0.00 7 99.950 0.00 0.00 0.00 0.00 8 99.950 0.00 0.00 0.00 0.00

Maximum out-of-plane deflection = 0.01

* = measured elevation *HI (Height of Instrument) Z = calculated ridged body tilt (in) U = out-of-plane settlement = S = out-of-plane deflection z-y Y = yield sterength of shell material (PSI) = 36,000 (A 36) E = Youngs modulas of elasticity (lbf/in2) = 29*10^6 S allowable (in) (API 653 B.3.2.1) = (L^2*Y*11)/(2EH) = 0.02 ft

R^2 = (Syy - SSE) / Syy = 0.95 >= 0.9 therefore, the curve is valid.

Since the maximum out-of-plane defection (S) is less than the maximum allowable S, the tank shell settlement is within acceptable limits.

-0.01

0.00

0.01

0.02

0.03

0.04

0 2 4 6 8 10

SHELL THICKNESS CALCULATIONS

Job No.: 20-056.03

Job Title: Inspect ASTs McGuire ANG

Subject: FAC 33-57 Shell Calculations

By: Mike O'Connor Date: 11/12/20

API-12C

API 653

SHELL CALCULATIONS

Diameter 31 feet Wind Velocity 125 mph Shell Height 41.25 feet Freeboard 3.8333 feet Nom Shell Thk 0.250 Design Fill Heigh 37.42 feet Specific Gravity 0.84 API650 Maximum height of unstiffened shell: 100.1 feet

0.84 API 653

Joint Efficiency 1.00 API650 Material A36 Yield Strength 36,000 psi Tensile Strength 58,000 psi (assumed)

Original Design Corrosion Allowance

0.062 in

Required thickness Lower Upper

Two CoursesCourses

Allowable Stress 24882 27376

Height Product Required Thickness Course (feet) Depth 1/4" min

5 6.16 14.50

4 5.96 20.46

3 5.96 26.42

2 5.96 32.38

1 5.04 37.42 min 2020 Corrosion Estimated UTM Visual current net 1994 Rate Service Life Inspection Inspection

Course UTM* thick Thickness * in/yr yrs. Interval Interval 5 0.249 0.249 0.266 0.001 >30 15 5

4 0.249 0.249 0.276 0.001 >30 15 5

3 0.253 0.253 0.265 0.000 >30 15 5

2 0.255 0.255 0.256 0.000 >30 15 5

1 0.249 0.249 0.258 0.000 >30 15 5

* The original thicknesses are assumed based on required design thicknessess, overtolerance and the range of the UTMs.

P.O. Box 4800 4800 W. Hundred Road Chester, Virginia 23831 Phone: 804-748-8746 Fax: 804-748-7849 www.brockenbrough.com

API-653

Original Design

0.100

0.100

2.6HDG

SE

(psi) 2.6(H-1)D

0.136

0.119

0.100

0.154

0.101

0.102

0.118

API-650

Original Hydro

24857.1428623200

0.168

0.044

0.063

SESE

2.6(H-1)DG

0.100

0.100

0.082

SHELL, NOZZLE, AND ROOF UT MEASUREMENTS

Job No.: 20-056.03

Job Title: Inspect ASTs McGuire ANG

Subject: FAC 33-57 UT Data

By: Mike O'Connor Date: 11/12/20

UTM DATA (0.001 inches)

UTMs Taken From Stairway Roof UTMs

Fifth Shell Course 255 254 253 258 297 249 262 287 256 254 256 251

Fourth Shell Course 249 289 290

Third Shell Course 253 257 285

Second Shell Course 257 256 255

First Shell Course

Typical First Shell Course UTMs.

1 4 7 2 5 8 3 6 9

1 2 3 4

1-1 256 255 INS-1 284

1-2 255 255 INS-1 284

1-3 252 251 INS-1 276

1-4 254 257 256 258 1-5 255 256 252 259 1-6 249 250 256 1-7 255 266 259 256 1-8 255 269 256 255 1-9 251 260 252 252

Insert Plates 268 267 264

Shell Nozzle UTMs

Nozzle Number Function Neck Reinforcing Plate B 10-inch Issue 252 D 36-inch Manhole 386 249…