Attachment J - Atlantic City-Fac 1022 (Tank 2)-FINAL-2021.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service Inspection Report

Atlantic City Air National Guard, New Jersey Facility 1022

Tank 1

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

USACE POL-MCX

10 May 2021

API 653 In-Service Inspection Report Atlantic City Air National Guard, 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 Inspections

4. Previous Repairs

5. 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 EVALUATION

SHELL AND ROOF LAYOUT DRAWINGS

OSHA ACCESS STRUCTURE REPORT

APPENDIX ‘B’: SHELL ROUNDNESS, PLUMBNESS AND SETTLEMENT SURVEYS

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 Atlantic City Air National Guard Base located at the Atlantic City International Airport, Egg Harbor Township, New Jersey. An API 653 In-service (visual external) Inspection was conducted for Facility No. 1022, on February 10, 2021. 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. 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 1022 is a 53-foot 6-inch diameter by 15-foot 1-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 in 1989 by CBI NA-Con, Inc. in accordance with API 650, 8th Edition. The tank has a Petrex aluminum internal floating pan. Secondary containment consists of concrete dike walls and basin. Details of tank construction and appurtenances are included in the Tank Information Table at the end of this Section.

Accessible areas of this tank were found to be in generally fair condition, with no mandatory repairs noted, and suitable for continued service. However, the top of the tank’s ringwall foundation, tank bottom external projection, and tank bottom-to-foundation seal are covered with a fabric mastic (rain shield), which prevented inspection of the top of the foundation, tank bottom projection, and tank bottom to foundation seal.

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 1022 should be performed by February 2026. Ultrasonic thickness inspection of the shell should be performed by October 2026 per the 2011 out-of-service inspection. Also, per the 2011 out-of-service inspection report, the next API 653 Out-of-service (internal) Inspection should be performed by October 2031. 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: 10 February 2021

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

Inspector(s): Mike O’Connor

STATE REGULATIONS

State Regulation for API In-Service Tank Inspections February 2026 State Regulation for API Out-of-Service Tank Inspections October 2031

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: October 2011 API In-Service (External) Inspection Date: Record not available

RECOMMENDED FUTURE INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: October 2031 API Ultrasonic Thickness Inspection of Shell Date: October 2026 API In-Service (External) Inspection Date: February 2026

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

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner New Jersey Air National Guard Location Atlantic City Air National Guard Base Facility Number 2022 Tank Number Tank 1 State / Country New Jersey / U.S.A.

City Egg Harbor Township Inspection Date 10 February 2021 Tank Manufacturer CBI NA Con, Inc.

Design Standard API 650 – 8th Edition (assumed) Date of Construction 1989 (per nameplate) Tank Contents Jet A (F-24) Tank Serial Number unknown Tank Diameter 53’-6” Shell Height 15’-1” Overflow Height 12’-6” Tank Capacity 5,000 BBL nominal, 3,490 BBL (LLA to HLA).

Foundation 20” tall concrete ring wall.

Construction and Material

Bottom Lap-welded 3/8” thick carbon steel plate (per 2011 inspection report).

Shell Two 1/4" thick butt welded carbon steel courses of plate (per 2011 inspection report).

Floating Roof Petrex aluminum internal floating pan.

Fixed Roof Lap welded steel cone roof.

Cathodic Protection None. Corrosion monitoring Electrical Resistance Probes (ERPs) and Vapor Corrosion Inhibitors (VCIs) under tank bottom.

Interior Coating System Epoxy 100% (assumed)

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

Level Gauging Enraf ATG, Vito water probe, manual gauging well, Varec 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 stainless steel Issue 8” Welded stainless steel Low Suction 2” Welded stainless steel Water Draw-off 1” Welded stainless steel

Level Alarms Shell mounted (independent) high, high-high, low and low-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 1021 and 1022 located at the Atlantic City Air National Guard Base, located at the Atlantic City International Airport in Egg Harbor Township, New Jersey. For Facility 1022, an API 653 In-service (external) Tank Inspection was performed on 10 February 2021. The inspection included a shell settlement evaluation and shell roundness and plumbness surveys.

2. Site Information

Established in 1958 at Atlantic City International Airport , the Atlantic City Air National Guard Base is home to the 177th Fighter Wing (177 FW), an Air Combat Command (ACC)-gained unit of the New Jersey Air National Guard, operating the F-16C/D Fighting Falcon. The 177th Fighter Wing is comprised of the 177th Headquarters Group, the 177th Mission Support Group, the 177th Maintenance Group, the 177th Operations Group, the 177th Medical Group and the 119th Fighter Squadron.

3. Previous Inspections

The previous API 653 Out-of-service inspection report recommended the next API 653 Out-of-service inspection for Tank Facility 1022 to be performed by October 2031, or October 2021 if UFC criteria govern. The inspection also noted and recommended removal of the “rain shield around the tank perimeter covering the exterior bottom to shell weld and chime.”

4. Previous Repairs

Previous repairs appear to include demolition of the original 3-inch ATG roof nozzle and four 2-inch shell holes (overflows) and installation of a new 1-foot by 2-foot shell overflow, a 3-foot by 4-foot internal ladder access hatch, two 18-inch by 24-inch roof vent/inspection hatches, the 6-inch water probe roof nozzle, the 10-inch ATG and manual gauging roof nozzles, 1-inch independent low, low-low, high, and high-high level alarm shell nozzles, 2-inch water draw off and return shell nozzles, and the product saver tank. The above mentioned repairs appear to have been performed after the 2011 out-of-service inspection. A stencil on the exterior of the shell indicates unspecified repairs were completed in 2015.

5. Future Projects

Facility personnel report that USACE Huntsville District project ATL-TTM-014 will replace the threaded carbon steel TRV and PRV drain piping currently routed from the pumphouse to Tank Facility 1021 with new stainless steel piping routed to both Tank Facilities 1021 and 1022.

https://en.wikipedia.org/wiki/Atlantic_City_International_Airport https://en.wikipedia.org/wiki/177th_Fighter_Wing https://en.wikipedia.org/wiki/Air_Combat_Command https://en.wikipedia.org/wiki/New_Jersey_Air_National_Guard https://en.wikipedia.org/wiki/New_Jersey_Air_National_Guard https://en.wikipedia.org/wiki/F-16_Fighting_Falcon

B. TANK INSPECTION COMMENTS

1. Tank Construction Tank Facility 1022 is an aboveground, vertical, storage tank, with a cone roof and aluminum internal floating pan. The tank is 53 feet 6 inches in diameter, 15 feet 1 inch tall, and has a nominal capacity of 5,000 BBLs. The nominal capacity of the tank from the bottom of the shell to the overflow is calculated to be approximately 5,000 BBLs. The useable capacity of the tank from the low level alarm to the high level alarm is calculated to be approximately 3,500 BBLs. The manufacturer’s nameplate indicates the tank was erected to API 650 - 8th Edition in 1989 by CBI NA Con, Inc.

2. Tank Foundation The perimeter of the bottom rests on a 20-inch tall concrete ringwall, with four leak detection tell-tales.

Two of the tell-tales are fitted with 3/4-inch plastic ball valves. Two of the leak detection tell-tales are fitted with Corrosion monitoring Electrical Resistance Probes (ERPs), Vapor Corrosion Inhibitors (VCIs) and 3/4-inch plastic ball valves. The underside of the tank bottom is not cathodically protected.

The top of the tank’s ringwall foundation, tank bottom external projection, and tank bottom-to-foundation seal are covered with a fabric mastic (rain shield), which prevented examination of those areas. The 2011 out-of-service inspection report identified the rain shield and recommended the removal of the fabric mastic (rain shield) as a Mandatory Repair, which does not appear to have been addressed. The fabric mastic does not shield the tank bottom external projection or bottom-to-foundation from rainwater that runs down the shell, but rather guides the rainwater from the shell into that area. The fabric mastic traps rainwater against the tank bottom external projection, promotes corrosion, prevents examination and maintenance of the aforementioned areas, and could hide critical defects and deterioration that may result in serious consequences.

The inspection included a shell settlement survey 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 are within acceptable limits of API 653.

3. Tank Shell The vertical and cylindrical shell consists of two butt welded courses. The 2011 out-of-service inspection report included a record of ultrasonic thickness measurements and indicated the shell had more than 30 years of remaining life at that time. The 2011 report also recommended the next UT examination of the shell to be completed within 15 years (before October 2026). 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 or 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 7/8 inches for this 15-foot 1-inch tall tank.

The maximum measured out-of-plumbness was approximately 1 1/16 inches toward the tank center measured on the north side. The out-of-plumbness of the shell exceeds the acceptable limit 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.

However, the shape of the shell appears to be within the allowable API 650 tolerance of plus or minus one inch of a new tank shell radius measured one foot above the tank bottom.

4. Tank Appurtenances

a. Cone Roof The tank roof is a lap-welded cone roof, constructed out of steel plate. Access to an internal ladder is gained through a 3-foot by 4-foot hatch.

b. Gauging The tank’s Enraf ATG is installed through a 10-inch roof nozzle and an 8-inch stilling well. The 8-inch aluminum manual gauge well is installed through a 10-inch roof nozzle and is fitted with a floating plug retriever. The tank also has a Varec autogauge. The autogauge appears to agree with the ATG to within 7/16 inches. However, there is condensation on the inside of the reading window.

c. Level Alarms The tank has shell mounted (independent) high, high-high, low, and low-low level alarms. The tank also has redundant ATG alarms.

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. However, the lowest step is approximately 11 1/2 inches above the concrete approach steps, and the rise of the top concrete approach step is 9 inches while the lower step is also 11 1/2 inches. OSHA requires stairway steps to have a consistent rise from ground level to a landing.

e. Grounding and Bonding The tank’s four grounding cables appear to be in good condition and are welded to carbon steel lugs, which are welded to the tank shell.

5. Tank Coating A stencil on the exterior of the shell indicates new coatings were provided in 2015. The tank’s coatings were evaluated for deterioration. No deterioration of the external coatings was apparent. However, there is much mold/mildew streaking on the north side of the shell.

6. Tank Piping Systems Facility 1022 is an operating tank. The tank receives fuel from the truck off-load stations located adjacent to the pumphouse. Fuel is issued to the nearby truck fillstands through the adjacent pumphouse. The receipt and issue piping are aboveground stainless steel. There generally appears to be adequate thermal relief throughout the piping system. However, the issue piping thermal relief valve is set at 180 psi, which may be higher than necessary. In addition, there is no thermal relief on the low suction piping, and the body cavity integral relief valve on the low suction nozzle double block and bleed valve relieves way from the tank and into the low suction piping, which has a ball valve on its connection to the main suction. There are no sample points on the receipt and issue nozzle necks or on the product piping. The product saver tank and water draw-off and return piping are stainless steel.

There are electrical isolation flanges between the carbon steel water draw-off and return nozzle DBBs and the stainless steel piping to product saver tank. However, there is no ground cable on the product saver tank.

7. Fire Protection System There are two fire hydrants in the vicinity. In addition, there are two AFFF chambers on the tank.

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 active duty 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 AFFF system is currently out-of-service but not currently scheduled for demolition.

8. Secondary Containment Secondary containment consists of concrete dike walls and basin. The secondary containment was evaluated during the inspection. The secondary containment is of sufficient size to contain a total tank loss as required by NFPA 30, 29CFR1910.106, and 40CFR112. To meet the UFC requirement of tank volume, plus one foot of freeboard, the dike walls would have to be raised approximately 12 inches. In addition, and contrary to NFPA 30, the dike drain does not appear to be on the low side of the dike basin, liquid collects on the other corners of the dike other than that of the dike drain, the dike basin generally does not slope away from the tank, the dike basin does not slope away from the piping, and the piping is routed over the swale and near an near an undrainable area where liquid collects. And as much of the dike basin is undrainable, was covered with ice and/or snow, and was not accessible for examination, there may be areas of deterioration of the dike area that were not identified during this inspection. The dike basin is below grade and could be subject to ground water intrusion.

C. FINDINGS AND RECOMMENDATIONS

Tank Facility 1022 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. Remove Mastic Fabric and Provide a Tank Bottom to Foundation Seal OBSERVATION: The top of the tank’s ringwall foundation, tank bottom external projection, and tank bottom-to-foundation seal are covered with a fabric mastic (rain shield), which prevented examination of those areas. The 2011 out-of-service inspection report also identified the rain shield and recommended the removal of the fabric mastic (rain shield as a Mandatory Repair. The fabric mastic does not shield the tank bottom external projection or bottom-to-foundation from rainwater that runs down the shell, but rather guides the rainwater from the shell into that area.

The fabric mastic traps rainwater against the tank bottom external projection, promotes corrosion, prevents examination and maintenance of the afore mentioned areas, and could hide critical defects and deterioration that may result in serious consequences. In addition, there are conduit support channel mounted on the top of the ringwall foundation that interfere with inspection, application, and maintenance of the tank bottom-to-foundation seal.

REFERENCE: Guidance for new construction, provided in DoD Standard Design AW 78-24-26 includes a tank bottom-to-foundation mastic seal located between the “underside” of the tank bottom and the foundation. API 653 and UFC 3-460-03 require the tank bottom extension and tank bottom-to-foundation seal to be regularly inspected. UFC 3-460-03 requires the coating on the tank bottom extension and condition of the tank bottom-to-foundation seal to be maintained.

RECOMMENDATION: Immediate removal of the fabric mastic (rains shield) covering the tank bottom extension, bottom-to-foundation seal, and foundation ringwall and inspection of those areas by a certified API 653 inspector should be considered of the highest importance for this tank. Repair the tank bottom as required. Reinstall the conduit support channel that is currently on the top of the concrete ringwall in a manner that does not interfere with the inspection, application, and maintenance of the tank bottom-to-foundation seal. Clean and coat the underside of the perimeter of the tank bottom with epoxy and provide a tank bottom-to-foundation seal between the underside of the perimeter of the tank bottom and the foundation. Do not cover the tank bottom extension or tank bottom-to-foundation seal with any substance except as recommended above.

b. Service the Varec Autogauge OBSERVATION: The inside of the reading window of the Varec autogauge is covered with condensation, which may eventually result in the reading window becoming cloudy and unreadable. The condensation on the inside of the reading window indicates there is condensate inside the autogauge head, which will promote corrosion and deterioration of the mechanisms inside the autogauge head and cause it to fail.

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).

RECOMMENDATION: Service the autogauge head. Add removing the condensate from the inside of the autogauge head to the periodic maintenance schedule. Refer to the autogauge maintenance manual for guidance.

c. Seal the Dike Area OBSERVATION: While no deteriorated expansion joint seals or cracks in the dike basin were identified by this inspection. As much of the below grade concrete dike basin is undrainable and much of the dike basin was covered with ice and/or snow and was not accessible for examination at the time of the inspection, there may be areas of deterioration of the dike basin that were not identified during this inspection. Ice in the dike area makes operation and maintenance of the tank hazardous.

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 sealing cracks and replacing failed expansion joints. OSHA requires employers to provide a safe working environment.

RECOMMENDATION: When the weather permits, remove the undrainable water from the dike area, document any areas where groundwater may be entering the dike, examine the dike area, seal any cracks, and replace any failed expansion joints sealants in the dike area as required.

Dry Dike Drain

ICE

Dry Dike Drain Behind Tank

Areas Where Liquid Collect

PST

PST

ICE

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. Clean the Roof and Shell OBSERVATION: There is black mold on the roof and north side of the shell.

REFERENCE: UFC 3-460-03, Appendix ‘F’ (Monthly Tank Inspection Checklists) requires Facility personnel to inspect for evidence of corrosion. 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 and north side of the shell to remove the black mold in the periodic maintenance schedule. Apply an environmentally friendly and approved mold inhibitor to the roof and shell.

b. Continue to Remove Leaves, Debris, and Soil Regularly OBSERVATION: The dike area is below grade. Leaves, debris, and soil collect in the dike area.

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: Continue to remove the leaves, debris, and soil from the dike area regularly.

c. Replace the Secondary Containment OBSERVATION: The secondary containment is of sufficient size to contain a total tank loss. To meet the UFC requirement of tank volume, plus one foot of freeboard, the dike walls would have to be raised approximately 12 inches. In addition, and contrary to NFPA 30, the dike drain does not appear to be on the low side of the dike basin, liquid collects on the opposite side of the tank from the dike drain, the dike basin generally does not slope away from the tank, the dike basin does not slope away from the piping, and the piping is routed over the swale and near the dike drain. And as much of the dike basin is undrainable, there are likely many areas of deterioration in the dike basin that may not be identifiable or repairable. In addition, the dike basin is below grade and could be subject to ground water intrusion.

REFERENCE: NFPA 30, 29CFR1910.106, and 40CFR112 require secondary containment to be of sufficient volume to hold the contents of a full tank. NFPA 30 paragraph 22.11.2.4 and 40 CFR 112.7(c)(1) require dikes to be liquid tight. NFPA 30 paragraph 22.11.2.1 requires the dike basin to be sloped away from the tank for 50 feet or to the dike wall, whichever is less. NFPA 30 paragraph

22.12.2.1 requires the dike basin to also be sloped away from the piping for 50 feet. Guidance for the design of new tanks, provided in UFC 3-460-01, includes 12 inches of freeboard.

RECOMMENDATION: Redesign and replace the secondary containment in accordance with UFC 3- 460-01, NFPA 30, 29CFR1910.106, and 40CFR112.

Dry Dike Drain

Areas Where Liquid Collect

Dry Dike Drain Behind Tank

Piping

d. Demolish the AFFF Chamber, Piping, and Cannon System OBSERVATION: There are two fire hydrants in the vicinity. In addition, there are two AFFF chambers on the tank. 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 active duty 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 AFFF system is currently out-of-service but not currently scheduled for demolition.

REFERENCE: Guidance for new construction, provided in UFC 3-460-01 and NFPA 30, do not include or require AFFF for Class II liquids. Previously Air National Guard standards included AFFF chambers on jet fuel storage tanks but are under review. 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 chambers on the tank, piping and supports in the dike area, and components of the AFFF system outside the dike area.

AFFF Chamber AFFF Chamber

e. Modify Thermal Relief Piping OBSERVATION: The issue piping thermal relief valve is set at 180 psi, which may be higher than necessary. The low suction piping includes a DBB valve on the shell nozzle and a ball valve on the connection to the main suction. As the low suction is not connected to a filter-separator the ball valve is unnecessary. There is no thermal relief on the low suction piping. The body cavity integral relief piping on the low suction nozzle, the water draw-off nozzle, and the product return nozzle double block and bleed valve relieves way from the tank and into the piping. The low suction piping is isolated by the DBB and the ball valve.

REFERENCE: Guidance for new construction, provided in UFC 3-460-01 paragraph 9.3.5 includes thermal relief for any section of pipe that has the potential to be isolated. Paragraph 9-3.5.1 recommends a TRV set pressure of 10 percent above pump deadhead. Paragraph 9-3.5.2 includes discharging the relief valve to an atmospheric source such as a storage tank and using only balanced type thermal relief valves on cascading systems.

RECOMMENDATION: Replace the issue thermal relief valve with a valve set to relieve at approximately 50 psi. Replumb the integral body cavity relief piping on the low suction DBB valve to relieve into the tank. Replace the ball valve on the low suction connection to the main suction with a spool piece or replumb the low suction DBB integral relief piping to relieve the excess pressure from the low suction piping, as well as the DBB body cavity, into the tank.

Low Suction Ball valve

Low Suction DBB

f. Provide Dedicated Product Saver Tank Grounding OBSERVATION: The product saver tank (PST)and water draw-off (WDO) and return piping are stainless steel. There are electrical isolation flanges between the carbon steel WDO and return nozzle DBBs and the stainless steel piping to PST. However, there is no ground cable on the PST.

REFERENCE: Guidance provided in DoD Standard Design AW 78-24-27 and UFC 3-460-01 includes electrical isolation between the stainless steel PST piping and the CS tank nozzle valves, and a dedicated grounding system for the PST.

RECOMMENDATION: Provide a dedicated grounding system for the PST.

g. Provide a Cathodic Protection System OBSERVATION: The underside of the tank bottom is not cathodically protected. Two of the four leak detection tell-tales are fitted with 3/4-inch plastic ball valves. Two of the four leak detection tell-tales are fitted with Corrosion Monitoring Electrical Resistance Probes (ERPs), Vapor Corrosion Inhibitors (VCIs) and 3/4-inch plastic ball valves.

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

RECOMMENDATION: If the next out-of-service inspection or the current corrosion monitoring system indicates significant underside corrosion provide cathodic protection for the underside of the tank bottom.

SS

CS

Electrical Isolation

h. Provide Pipe Support OBSERVATION: There does not appear to be sufficient support under the receipt and under the issue piping near the ball joints closest to the tank. The weight of the piping is supported mostly by the level control valve.

REFERENCE: NFPA 30 paragraph 27.6.1 requires piping to be supported. DoD Standard Design 78- 24-27 includes an adjustable stanchion type pipe support near the ball joint nearest to the tank.

RECOMMENDATION: Provide adjustable or spring loaded stanchion type pipe supports under the receipt and under the issue piping near the ball joints closest to the tank.

Ball Joint

Conduit Support Conduit Support

Ball Joint

i. Relocate Upper shell Manhole and Stairway Landing OBSERVATION: The elevation of the lower stairway landing is approximately 52 1/2 inches above the tank bottom and appears to be right for accessing the upper shell manhole in its current elevation, 42 inches above the landing (per API 650), or 94 1/2 inches. However, the upper shell manhole appears to be too low to allow access to the internal floating pan at high leg level. There is no landing for accessing the shell mounted high level alarms and control float chamber. However, the stairway was made wider at the high level alarms to allow access and passage.

REFERENCE: Guidance for construction of new fuel tanks provided in DoD Standard Design AW 78- 24-27 includes a level of the upper shell manhole of 9 feet 9 inches (117 inches), with an access landing at approximately 75 inches. Guidance for new construction, provided in DoD Standard Design AW 78-24-27, also includes landings on circumferential stairways for accessing the high level alarms, controls.

RECOMMENDATION: Revise the high leg level of the internal floating pan, if necessary, to allow safe entry and access for internal inspection and maintenance. Modify the tank to provide an upper shell manhole approximately 42 inches above the high leg level of the internal floating pan. Modify the existing stairway or provide a new stairway and landings for accessing the new upper shell manhole, the high level alarms, level control float chamber and the tank roof.

j. Replace Approach Steps OBSERVATION: The rise of the circumferential stairway is approximately 9 inches. The rise of the concrete approach steps varies from 9 to 11 1/2 inches and the top approach step is approximately 11 1/2 inches below the bottom shell mounted stairway step.

REFERENCE: OSHA regulation 29 CFR 1910.25 (b) (3) (December 2017) requires the step rise to be uniform throughout any flight of stairs.

RECOMMENDATION: Replace the existing approach steps below the tank’s circumferential stairway with approach steps that conform to OSHA and provide a continuous rise consistent with the tank’s circumferential stairway.

k. Eliminate Threaded Connections and Copper Alloy Valves OBSERVATION: The 2-inch threaded sample and camlock shell nozzles have copper alloy valves.

REFERENCE: NFPA 30 paragraph 27.4.3 and UFC 3-460-01 paragraph 3-6.7.1 prohibit valves made of low melting point materials. Guidance for new construction provided in UFC 3-460-01 paragraph 9-8. e) prohibits threaded connections. Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes fuel sample connectors on the product nozzles.

RECOMMENDATION: Eliminate the 2-inch threaded sample and camlock shell nozzles.

l. Provide Sample Points OBSERVATION: There are no sample points on the product nozzles or piping.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes fuel sample connectors on the product nozzles.

RECOMMENDATION: Provide sample points (fuel sample connectors) on the receipt and issue nozzles.

m. Provide Lighting OBSERVATION: Facility personnel indicate lighting at the facility focuses mainly on the paved vehicle traffic areas and that lighting is inadequate inside the diked area of the tank.

REFERENCE: Guidance for new construction provided in UFC 3-460-01 paragraph 2-11.2 includes providing lighting (illumination) for all working areas for night operations.

RECOMMENDATION: Provide lighting sufficient for night operations.

n. Confirm SPCC Plan OBSERVATION: Facility personnel provided documentation dated November 24, 2020 indicating the New Jersey Department of Environmental Protection had approved the Facilities Discharge Prevention, Containment and Countermeasure (DPCC) and Discharge Cleanup and Removal (DCR) Plans for a period of three years. The tanks appear to be referenced in a document so titled and dated September 2020. While pages from that document bearing a Professional Engineer’s signature and seal were not provided it is taken in good faith that it exists and was only beyond the Facility Personnel’s administrative authority to provide it.

REFERENCE: 40 CFR 112.1 (a) (2) and 40 CFR 112.7 (3) requires an SPCC plan that addresses each oil container with capacity of 55 gallons or greater.

RECOMMENDATION: Confirm the existence of the SPCC Plan and Professional Engineers signature in accordance with 40 CFR 112.

FAC 1022

FAC 1022

APPENDIX ‘A’: ENGINEERING CALCULATIONS AND DRAWINGS

SHELL SETTLEMENT EVALUATION

Austin Brockenbrough & Associates, L.L.P. Job No. 20-056.01 Location: Atlantic City ANG Date: 3/19/21 Subject: Tank 1022 - 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) = 53.5 (ft) Number of equally spaced data points (ft)= 8 L = Arc length between measurement points (ft) = 21.01 Tank Height (H) = 15.0 (ft)

Relative elevation of lowest horizontal weld seam. (ft)

* Z U S

0 99.960 0.00 0.01 0.01 0.01 1 99.990 0.03 0.01 -0.02 -0.01 2 100.000 0.04 0.03 -0.01 -0.01 3 99.990 0.03 0.04 0.01 0.01 4 100.000 0.04 0.04 0.00 0.00 5 100.000 0.04 0.04 0.00 -0.01 6 99.980 0.02 0.03 0.01 0.00 7 99.970 0.01 0.01 0.00 0.00 8 99.960 0.00 0.01 0.01 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) = 30,000 (unknown material) E = Youngs modulas of elasticity (lbf/in2) = 29*10^6 S allowable (in) (API 653 B.3.2.1) = (L^2*Y*11)/(2EH) = 0.17 ft

R^2 = (Syy - SSE) / Syy = 0.66 not >=0.9 therefore cosine curve is invalid.

Evaluation by the Arc Length Method described in API 653 B.2.2.5.1 is required.

Location: Atlantic City ANG Date: 3/19/21 Subject: Tank 1022 - Shell Settlement Evaluation By: Mike O'Connor

API 653 B.2.2.5.1 Evaluation by Settlement Arc Length Method

* Open top (yes/no) = yes Per B.3.2.2, K = 7.8

Settlement arc length (ft), Sarc Out of plate settlement at Point i (Si) Allowable settlement at point i (Smax) = MIN[K*Sarc*(D/H)*(Y/E), 4]

Point Sarc (ft) Si (ft) Smax (ft)

1 105.0 0.04 0.25 OK

3 42.0 0.01 0.10 OK

* For the purpose of this evaluation tanks with geodesic domes and barn roofs are consided to be open top, as those types of roofs do not significantly restrain the top of the shell.

Si < Smax →

Evaluation of the settlement by the arc length method indicates the settlement is within acceptable limits.

Si < Smax →

0.00

0.01

0.02

0.03

0.04

0.05

0 2 4 6 8 10

Measured Elevation (ft)

Si0 Si3

Best Fit Cosine Curve

SHELL AND ROOF LAYOUT DRAWINGS

TANK 1022 SHELL LAYOUT

ATL-1022

ATL-1022

TANK 1022 ROOF LAYOUT

OSHA ACCESS STRUCTURE REPORT

OSHA Circumferential Stairway Data

OSHA Rq’d Actual

(in) min (in) max (in)

Handrail Height 33 OK 30 34 Step Width 28 OK 22 NA

Step Rise 9 OK 6 1/2 9 1/2 Bottom Step (Transition) Rise 11 1/2 NOT OK 8 9 1/2

Top Approach Step Rise 9 OK 8 9 1/2 Bottom Approach Step Rise 11 1/2 NOT OK 8 9 1/2

BOTTOM STEP

RISE

APPENDIX ‘B’: SHELL ROUNDNESS, PLUMBNESS AND SETTLEMENT SURVEYS

Location: Atlantic City ANG Date: 2/19/21 Subject: Shell Radius Survey Tank Facility 1022 (Tank 1) Page 1 of 3

Measured Circumference at Bottom = 168.07 Calculated Diameter = 53.50

Calculated Radius = 26.75

Distance From Radial

Centerline Deviation Deviation (in) South 26.75 0.00 0.00 14.8 S+N 1.07

26.76 0.01 0.13 12.3 1.12

26.76 0.01 0.12 9.3 0.77

26.75 0.00 -0.01 6.3 0.28

26.76 0.01 0.16 3.3 0.60

26.74 -0.01 -0.10 0.3 -0.08

Chime Elevation----> 100.00 Southeast 26.71 -0.04 -0.51 14.6 SE+NW 0.08

26.75 0.00 -0.01 12.3 0.84

26.74 -0.01 -0.09 9.3 0.63

26.75 0.00 0.01 6.3 0.74

26.74 -0.01 -0.08 3.3 0.12

26.74 -0.01 -0.07 0.3 0.43

Chime Elevation----> 100.00 East 26.76 0.01 0.11 14.7 E+W -0.24

26.76 0.01 0.07 12.3 0.32

26.78 0.03 0.41 9.3 0.58

26.79 0.04 0.44 6.3 0.68

26.76 0.01 0.08 3.3 0.13

26.76 0.01 0.10 0.3 0.25

Chime Elevation----> 99.98

Height Above Chime diameter deviation (in)

Subject: Shell Radius Survey Page 2 of 3

Distance From Radial

Centerline Deviation Deviation (in) Northeast 26.73 -0.02 -0.23 14.9 NE+SW 1.30

26.78 0.03 0.37 12.3 1.99

26.78 0.03 0.36 9.3 1.86

26.77 0.02 0.19 6.3 1.47

26.76 0.01 0.14 3.3 1.30

26.77 0.02 0.21 0.3 1.07

Chime Elevation----> 99.97 North 26.84 0.09 1.07 14.2

26.83 0.08 0.99 12.3

26.80 0.05 0.65 9.3

26.77 0.02 0.29 6.3

26.79 0.04 0.45 3.3

26.75 0.00 0.01 0.3

Chime Elevation----> 99.96 Northwest 26.80 0.05 0.59 14.2

26.82 0.07 0.85 12.3

26.81 0.06 0.73 9.3

26.81 0.06 0.73 6.3

26.77 0.02 0.20 3.3

26.79 0.04 0.50 0.3

Chime Elevation----> 99.99

Height Above Chime diameter deviation (in)

Subject: Shell Radius Survey Page 3 of 3

Distance From Radial

Centerline Deviation Deviation (in) West 26.72 -0.03 -0.35 14.4

26.77 0.02 0.25 12.3

26.76 0.01 0.17 9.3

26.77 0.02 0.24 6.3

26.75 0.00 0.05 3.3

26.76 0.01 0.16 0.3

Chime Elevation----> 100.00 Southwest 26.88 0.13 1.53 14.2

26.88 0.13 1.62 12.3

26.87 0.12 1.49 9.3

26.86 0.11 1.28 6.3

26.85 0.10 1.15 3.3

26.82 0.07 0.86 0.3

Chime Elevation----> 99.99

Height Above Chime

APPENDIX ‘C’: API 653 CHECKLISTS FOR TANK INSPECTIONS

UL SWRI

API Other

Protected

Type: Type:

Size: Date Installed:

Stainless steel End Conn: Size: 8" Material: Stainless steel End Conn: Size: 8"

Issue To:

Release Prevention Barrier

Overfill Protection / Level Alarms:

high, high-high, low, low-low 8" hydraulic operated level control valve

Receipt Piping Configuration Issue Piping Configuration Tank Piping

Secondary Containment

October 1, 2011

Tank Specifications

Previous Tank Inspection Date:

Continuous Release Detection Monitoring

Type:

Date Installed:

Current Product:

53'-6" Dia by 15'-0" tall

NA

Inspection Date:

Design Std

Tank Inspector Name:

Inspector Certification Number:

Original

(4) 2" Leak detection tell-tales

Original

Welded

Truck fill stands

FML Assumed

API 653 EXTERNAL INSPECTION CHECKLIST

Atlantic City ANGProject Site:Project Name:

Project Location:

Brockenbrough Job No.:

SPCC AST Inspecitons Various Locaitons

General Inspection Information 20-056.01

Submitted to:

Contract No.:

USACE EXWC Omaha W9128F- 17- D-0017

Tank Construction and Configuration

Insulated

Coated

Plastic / Fiberglass

Other:

Jet A

5,000 BBL

3,390 BBL

Fire Resistant

Tank Facility No.:

Local Tank ID No.:

February 10, 2021

Facility 1022

Tank Manufacturer:

Tank Construction Date:

Tank #1 Mike O'Connor

Vertical

Rectangular

Double Wall

Closed Top Dike

Change of Service:

Last Repair:

Tank Coatings:

Exterior Coating:

Epoxy/Poly (assmed) Coating replaced 2014

Epoxy (assumed) Coating replaced 2014

Interior Coating:

Double Bottom

Unknown

1989 (per previous report)

Concrete dike walls and basin

45" by 77' by 102'

Level Alarms:

Material:

Tank Outside Dimensions:

Nominal Capacity:

Useable Capacity:

Overfill Protection:

Secondary Containment, Overfill, and CRDM

Welded

Horizontal Single Wall

Open Type Dike

Receipt From: Truck offload stands

Level alarms and stilling wells between 2011 and 2020.

API 653 EXTERNAL INSPECTION CHECKLIST

Atlantic City ANGProject Site:Project Name: SPCC AST Inspecitons

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

TASK

Check for:

Tank Settlement

C.1.1.4 Rock

Measure foundation levelness and bottom elevations (See Annex B) c)

Check for:

STATUS COMMENTS

Dike drain is locate at south corner. However, water collects on the west and east corners of dike area. Dike basin not sloped away from tank all the way to dike wall.

a)

b) C.1.1.6 Housekeeping

Build-up of trash, vegetation, and other inflammables

ITEM

C.1.1 Foundation

C.1.1.1 Concrete Ring

Leaching of oil which has left rock filler exposed indicating hydrocarbon leakage

Tank settlement into asphalt base

C.1.1.7 Cathodic Protection

Site drainage away from the tank, associated piping, and manifolds

Check for:

Check for:

Presence of crushed rock under the steel bottom which usually results in severe underside corrosion.

Cavities under foundation; vegetation against bottom of tank

Broken concrete, spalling, and cracks, especially under backup bars used in welding butt-welded annular rings under the shell Indications of bottom leakage at drain openings in ring, back of water-draw basins, and top surface of ring

Review cathodic protection potential readings

Run-off rainwater from shell draining away from the tank

Check for :C.1.1.3 Oiled Dirt or Sand b)

Settlements into the base

C.1.1.2 Asphalt

e) Settlement around perimeter of tank

C.1.1.5 Site Drainage

Check for:

Proper operation of dike drains d) a) b) a)

None.

Dike drain is locate at south corner. However, water collects on the southeast side under piping and west corner. Dike basin not sloped away from tank or piping.

Leaves collect in dike area.

C.1.2.1 External Visual Inspection

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A No access.

C.1.2.3 Riveted Shell Inspection

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Tank bottom extension and tank bottom-to-foundaiton seal are covered with a fabric seal and are not accessible. Conduit support channels installed on top of ringwall interfers with bottom to foundation seal and its repair.

Rivet and seam leaks on external surface

Check for:

Corrosion and thinning on plate and weld after cleaning the bottom angle area

Paint failures, pitting, and corrosion

Full fillet lap-welded vertical seams to increase joint efficiency b) c) c)

C.1.2.4 Wind Girder (Floating Roof Tanks) a)

Check for:

Broken welds and corrosion damage (paint failure, pitting, corrosion, product build-up), especially where it occurs at tack-welded junction d)

Grooving, corrosion, pitting, and coating failures b)

Corrosion loss and wear on the rivets

Reinforcing pads welded to shell at supports

Leaks and identify the location by sketch or photo

Check for:

Pitting on support welds to shell, especially on shell plates

a) b)

c) Bottom-to-Foundation Seal

e) Drawings of riveted seams if available. Otherwise, dimension and sketch (or photograph) the rivet pattern: no. of rows, rivet size, pitch length, butt-riveted or lap-riveted joints a)

C.1.2. Shells Check for:

C.1.2.2 Internal (Floating Roof Tank)

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

ITEM TASK

a) Leaks at piping manifolds, flanges, and valves

Flange leaks and leaks around bolting

Shell plate dimpling around nozzles, caused by excessive pipe deflection c)

Check for:

C.1.3.3 Autogauge System Check for:

b)

COMMENTS

Cracks or signs of leakage on weld joint at nozzles, manholes, and reinforcing plates

Fire fighting system componentsb) c) d) e) f)

Damage on welds on shell-mounted davit clips above valves 6 inches and larger g)

Anchored piping which would be hazardous to the tank shell or bottom connections during earth movement

Adequate thermal pressure relief of piping to the tank Proper operation of regulators for tanks with purge gas systems Leaks at sample connections and proper valve operation Damage and test the accuracy of temperature indicators h)

Issue and recipt TRVs 180 psi.

C.1.3.1 Manholes and Nozzles

C.1.3.2 Tank Piping Manifolds

C.1.3 Shell Appurtenances

Sealing of insulation around manholes and nozzles

e) Adequate manholes flange and cover thickness on mixer manholes d) a)

Check for:

STATUS

a) Leaks on autogauge tape guide and lower sheave housing (floating swings)

b) Damage on autogauge head Condensation on inside of window.

Pass Fail N/A

Pass Fail N/A 1" CS pipe

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

Pass Fail N/A

c) Pass Fail N/A

Pass Fail N/A

Pass Fail N/A Pass Fail N/A

Pass Fail N/A

h) Condition of board and legibility of board-type autogauges Freedom of movement of marker and float

C.1.3.3 Autogauge System c) d)

C.1.3.4 Shell-mounted Sample Station a) b)

Check for:

Function of valves and plugging in sample lines, including drain or return-to-tank line Leaks in circulation pump and operating problems

Inspect condensate drain for presence of oil indicating leakage

C.1.3.5 Heater (Shell Manhole Mounted) C.1.3.6 Mixer Check for:

c) Condition of power lines and connections to mixer

Bracing and supports for sample lines and equipment

a) b)

Proper mounting flange and support Leakage i) e) f) g)

Proper movement of tape by bumping the checker on autogauge head Size and construction material of the autogauge tape guide and make note (floating roof tanks) Proper movement of tape. Ask the operator if the tape tends to hang up during tank roof movement (floating roof tanks).

Actual product level compared to the reading on the autogauge. Make note. (max. variation is 2 in.)

No more than 2 feet of tape are exposed…