Attachment J.1- Previous Inspection Report tank 4310.pdf

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

(USACE POL‐MCX)

2/13/2019

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION INFORMATION

EQUIPMENT USED

STATE REGULATIONS

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

B. TANK INSPECTION COMMENTS

1. Secondary Containment

2. Tank Construction

3. Tank Foundation

4. Tank Bottom

5. Tank Shell

6. Tank Floating Roof

7. Tank Fixed Roof

8. Tank Appurtenances

9. Tank Piping System

10. Fire Protection System

11. Cathodic Protection

12. Coatings

C. FINDINGS AND RECOMMENDATIONS

1. Mandatory

2. Short Term

3. Long Term

APPENDIX A: ENGINEERING CALCULATIONS

APPENDIX B: ENGINEERING DRAWINGS

APPENDIX C: ENGINEERING DATA

APPENDIX D: API STANDARD 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX E: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

ATG Automatic Tank Gauge

BBL Barrel

CFR Code of Federal Regulations

CP Cathodic Protection

DFT Dry Film Thickness

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

NACE National Association of Corrosion Engineers

NDT Non-Destructive Testing

NFPA National Fire Protection Association

PSI Pounds per Square Inch

PT Penetrant Testing

P/V Pressure/Vacuum

RP Recommended Practice

PST Product Saver Tank

RT Radiography Testing

STI Steel Tank Institute

TML Thickness Measurement Location

TRV Thermal Relief Valve

UFC Unified Facilities Criteria

UFGS Unified Facilities Guide Specifications

ULS Ultra Low Sulfur

UT Ultrasonic Testing

VT Visual Testing

GENERAL SUMMARY

An API Standard 653 out-of-service inspection of Tank 28 (Facility 4310), located at Robins AFB, GA was completed on February 13, 2019 to evaluate the tank’s integrity, collect data, and establish a database for future inspections and evaluations. The shell service life is greater than 30 years of remaining shell life under current conditions. The bottom service life is greater than 30 years of remaining bottom life under current conditions. Inspection Results are listed in section 4.0.

Recommendations for Compliance with API Standard 653 are listed in section 5.0. Other Recommendations are listed in section 6.0.

Significant Findings (overview):

Mandatory:

1. The projection of the bottom plate beyond the outside toe of the shell-to-bottom weld between the receipt line and issue line is less than the minimum requirement of 3/8-inch (measured zero inches). The shell-to-bottom weld and area is of the highest potential for catastrophic failure. The tank should not be placed back into service until this deficiency is corrected. Note:

Hydrostatic testing will be required.

2. The tank has Tracer Tightness probes through the ringwall for bottom leak detection. The bottom does not have cathodic protection, but does have a liner underneath. The probe near the manhole between the receipt line and issue line was inspected, and fuel was observed from the probe. The chime in the area of this probe has fuel wicking through the bottom-to-ringwall sealant. The bottom was MFE scanned and no underside corrosion was found. The bottom welds were inspected for any obvious defects for potential source of fuel underneath the bottom. The welds were coated and no obvious weld defects were found. The fuel under the

3. Twelve (12) lap-welded pipe support pads on the bottom do not have the required weld spacing of 2 inches as required by API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to

4. The floating roof anti-rotation anchor support pad is not at least six (6) inches with rounded corners. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to meet the minimum weld spacing requirements. Note: MT testing will be required on all future inspections until modified.

5. The 16-inch issue line is not resting on any of the internal pipe supports. The issue line extends to the sump. Shell deformation was noted around the reinforcement. Magnetic particle (MT) examination should be performed on the nozzle and reinforcement welds after the pipe is

6. The 8-inch receipt line is not resting on any of the internal pipe supports. Magnetic particle (MT) examination should be performed on the nozzle and reinforcement welds after the pipe is

7. The weld spacing between two (2) anchor chairs and the manhole reinforcement is less than the minimum requirement of API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to

8. The weld spacing between circumferential stairway tread and the shell horizontal weld at three

(3) locations is less than the minimum requirement of API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into

9. The weld spacing between circumferential stairway tread and the anchor chair is less than the minimum requirement of API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to

Short Term:

1. The secondary containment may not contain any spilled product from spilling into the environment due to hairline cracks. It is not known if the secondary containment has a liner underneath the concrete.

2. The sealant between the tank bottom and ringwall has failed in several locations. Base reported rain water is entering under the bottom.

3. The PVC sleeves of the ground cables through the secondary containment floor are not sealed.

4. The manual tape level gauge (MTG) is not functional. The tape broke free from the floating roof.

The bump check of the MTG failed. The MTG reads 54' 7-1/2".

5. The bolt and nut of the anchor chairs has coating failure and corrosion.

6. The flanges on the thermal relief line of the issue line have corrosion. Note: The relief line has two (2) sight glass flow indicators and both TRVs do not have a test TEE for annual testing.

7. The product save tank is not grounded.

8. The low level alarm assembly circuit has failed coating and corrosion on the flanges, piping, valves, and float chamber. The float chamber has inactive corrosion that measured 20-30 mils in depth.

9. The first step of the circumferential stairway is 18-1/2 inches high from the grade of the secondary containment floor.

10. The flanges and valves of the high level alarm assembly are heavily corroded.

11. The high level shut-off assembly piping has coating failure and minor corrosion.

12. The shell and chime have vegetation growth.

13. Both manways do not have davit arms as required by API standards.

14. The flanges on the thermal relief line of the receipt line have corrosion. Note: The relief line has two (2) sight glass flow indicators and both TRVs do not have a test TEE for annual testing.

15. The high level shut-off control valve is aluminum, which is low melting material.

16. The conduit at the chime has heavy corrosion.

17. The fixed roof has several areas indicating standing water and several areas of failed coating.

The entire roof has vegetation growth. The coating appears to have expired.

18. The circumferential stairway treads have coating failure and corrosion.

19. The roof circulation vents/inspection hatches have moderate corrosion and coating failure.

20. The roof manhole on the fixed roof has a broken bonding strap.

21. The roof manhole and hardware have heavy corrosion and coating failure. The manhole cover is warped and allows water intrusion onto the floating roof. The sealant around the stilling well penetration on the manhole cover allows water intrusion onto the floating roof.

22. The 24-inch center roof vent and hardware have minor corrosion and coating failure.

23. The 6-inch blanked nozzle and hardware on the fixed roof have heavy corrosion and coating failure.

24. The tank does not have a fire diamond label.

25. A hold-off distance is not stenciled on the roof adjacent to the sample location.

26. The tank does not have a facility ID label (e.g. 4310) on the shell.

Long Term:

1. Both double block and bleed valves of the 16-inch issue line do not have adequate clearance underneath for valve maintenance. The tank isolation skin valve clearance measured 12 inches.

2. The thermal relief system for the 16-inch issue line consists of 1-inch threaded piping and threaded flanges, two (2) TRVs with sight glass flow indicators. The TRVs do not have a test TEE for annual testing. The system is not stainless steel with welded fittings.

3. The configuration of the high level alarm assembly consists of 1-inch threaded carbon steel piping and fittings. The system is not stainless steel with welded fittings. The assembly does not have a drain line to the product saver tank.

4. The configuration of the high level shut-off assemblies consists of 1-inch threaded carbon steel piping and fittings. The system is not stainless steel with welded fittings. The assembly do not have a means for annual testing. The assembly does not have a drain line to the product saver tank.

5. The configuration of the low level alarm assembly consists of 1-inch threaded carbon steel piping and fittings. The system is not stainless steel with welded fittings. The assembly does not have a drain line to the product saver tank.

6. The thermal relief system for the 8-inch receipt line consists of 1-inch threaded piping and threaded flanges, two (2) TRVs with sight glass flow indicators. The TRVs do not have a test TEE for annual testing. The system is not stainless steel with welded fittings. The system has a section of ¾-inch pipe at the TRV outlet isolation valve.

7. The low suction line does not have a double block and bleed valve as the tank isolation skin valve. The shell nozzle is three inches with a 2-inch ball valve. The low suction line is carbon steel (internally and externally).

8. The water draw-off line does not have a double block and bleed valve as the tank isolation skin valve. The shell nozzle is one inch with a 3/4-inch ball valve. The water draw-off line is threaded carbon steel (internally and externally).

9. The clearance between the high level alarm assembly and circumferential stairway handrail does not have sufficient clearance. The clearance measured 16 inches. The circumferential stairway does not have a platform at the high level assemblies.

10. The 16-inch issue line does not have an anti-vortex plate and does not extend ½ the tank radius.

The line extends to the sump. The pipe supports do not have adjustable "H" type internal pipe supports with TEFLON coated U-bolts. The pipe supports are not touching the pipe and are not adjustable.

11. The 2-inch low suction line does not have adjustable "H" type internal pipe supports with TEFLON coated U-bolts. The pipe supports are not adjustable.

12. The 3/4-inch water draw-off line does not have adjustable "H" type internal pipe supports with TEFLON coated U-bolts. The pipe supports are not adjustable.

13. The 8-inch receipt line does not have adjustable "H" type internal pipe supports with TEFLON coated U-bolts. The pipe supports are not touching the pipe and are not adjustable.

14. The floating roof only has one anti-rotation device (minimum of two is required).

15. Both manholes do not have a filler drum to prevent floating roof seal damage.

16. The upper manhole has a hinged cover in lieu of a davit arm and does not have two (2) handles.

17. The tank does not have a sample gauge with slotted stilling well. The tank is manually gauged through the access hatch of the ENRAF ATG stilling well. The VITO water probe also is housed in this stilling well. Sounding the tank in the same stilling could damage the float of the ENRAF system it is not fully retracted. Full retraction of the float can take a long period of time and the operator should be trained by the manufacturer. The ENRAF probe is wrapped around the VITO cable.

18. The ENRAF and VITO systems are mounted on the internal ladder access hatch. The internal ladder cannot be used without disconnecting the ENRAF and VITO cables. The stilling well is part of the internal ladder and is not slotted. The internal ladder is near the shell. The VITO water probe is not mounted on a designated stilling well that is located near the sump. The ENRAF is not mounted on a designated stilling well.

19. The fixed roof does not have any scaffolding supports.

20. The circumferential stairway treads are welded directly to the shell and do not have reinforcement pads installed.

21. The roof premier handrail does not have a top rail at the roof circulation vents/inspection hatches. The top rail gap has a chain. The chain should be at the intermediate rail.

22. The bottom leak detection system is composed of PVC Tracer Tightness probes. The probes have plugs in the PVC sleeves.

23. The vertical members of the anchor chairs are not notched at the shell (top and bottom).

24. The tank does not have a cathodic protection system installed under the bottom.

INSPECTION INFORMATION

Inspection Date: February 13, 2019 Inspection(s) Performed: API-653 Out-of-Service Inspector(s): Wayne K. Bailey

EQUIPMENT USED

1. Equipment Type: Ultrasonic Thickness Meter

a. Manufacturer: General Electric

b. Model Number: DMS GO+

c. Calibration Method: Two Point Calibration

2. Equipment Type: Surveying Tool

d. Manufacturer: Leica

e. Model Number: 3D DISTO

f. Calibration Method: Manufacturer

STATE REGULATIONS

API-653 In-Service Tank Inspections: NA API-653 Out-of-Service Tank Inspections: NA

NOTE: If there are no state regulations for tank inspections, N/A shall reside in-place of the number of years between inspections. If state regulations reside, the recommended future inspections dates shall be based on whichever is more stringent between the STI inspector’s calculations and the state regulations.

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: January 21, 2009 API In-Service (External) Inspection Date: April 29, 2015

RECOMMENDED FUTURE INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: 10 years after bottom is repaired API In-Service (External) Inspection Date: February 2024

Signature(s):

Wayne K. Bailey, API-653 #1331 InterSpec, LLC.

Owner US Air Force Location Robins AFB Facility Number 4310 Tank Number 28 State / Country Georgia, United States City Warner Robins Inspection Date February 13, 2019 Tank Manufacturer Original: Advance Tank Company Modified: Weston Solutions, Inc.

Design Standard API Standard 650 8th Edition

Date of Construction Original: 1995 Modified: 2009 by Weston Solutions, Inc.

Tank Contents Jet A Tank Serial Number 3795A Tank Diameter 43’ 6” Shell Height 42’ 3” Product Height 38’ Tank Capacity 10,000 barrels (420,000 gallons) Foundation Concrete Ringwall

Construction

Bottom Lap-Welded/Butt-welded Annular Ring Shell Butt-Welded (Cylindrical) Floating Roof Fasteners Fixed Roof Lap-Welded

Material

Bottom Carbon Steel, A-36 Shell Carbon Steel, A-36 Floating Roof Aluminum Fixed Roof Carbon Steel, A-36

Cathodic Protection None Interior Coating System Thin Film Epoxy Exterior Coating System Thin Film Epoxy Level Gauging SHAND&JURS MTG, ENRAF ATG, and VITO Water & Temp Probe Overfill Protection Mechanical Automatic Shut-Off

Piping

Receipt 8" Carbon Steel Issue 16" Carbon Steel Low Suction 2” Carbon Steel Water Draw-Off 3/4" Carbon Steel

Level Alarms & Controls

Description ENRAF ATG Independent High-High Level Alarm: 35’ 00-00/16” 35’ 00-00/16” High-Level Alarm: 34’ 06-00/16” 34’ 06-00/16” Low-Level Alarm: 3’ 08-10/16” Unknown Low-Low Level Alarm: 1’ 10-06/16” Unknown High-Level Control Shut-off: 36’ 03-11/16”

Type of Floating Roof Full Contact, Aluminum Honeycomb Floating Pan

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection This project will perform API 653 inspections of various tanks at facilities throughout the United States. Additional consideration is given to federal, state, and local regulations as well as applicable military criteria and general industry standards.

An API Standard 653 Out-of-Service inspection was performed for Tank #28 (Facility 4310).

2. Site Information On February 13, 2019 Argus Consulting and our sub-consultant (InterSpec, LLC) performed an API 653 Out-of-Service inspection of Tank #28 (Facility 4310), located at Robins AFB, GA.

B. TANK INSPECTION COMMENTS

1. Secondary Containment 40 CFR 112.7(c) states that the entire secondary containment system, “including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system ... will not escape containment before cleanup occurs.” 40 CFR 112.8(c)(2) and 40 CFR 112.12(c)(2) state that diked areas must be “sufficiently impervious to contain oil.” The purpose of the secondary containment requirement is to prevent discharges, as described in 40 CFR 112.1(b); therefore, effective secondary containment methods must be able to contain oil until the oil is cleaned up. The secondary containment area consists of concrete floor and concrete vertical walls. An informal containment evaluation was conducted. The containment does appear to be of sufficient size to contain a total tank loss per UFC 3-460-01 Section 8-14.2.1, “The containment area needs to have sufficient capacity to contain the tank contents plus one foot of freeboard. If the containment has the capacity to contain the tank contents plus one foot of freeboard, the containment area is sufficient.” The secondary containment area appears to be properly graded to drain water away from the tank in accordance with NFPA 30. Several of the concrete pads of floor have hairline cracks. The PVC sleeves of the ground cables through the secondary containment floor are not sealed.

2. Tank Construction Tank #28 (Facility 4310) is a nominal 10,000 barrel, 43’ 6” diameter by 42’ 3” tall, Jet A, aboveground vertical storage tank. The original construction and upgraded nameplates were affixed to the tank. The upgraded nameplate is not readable. The tank was built by Advance Tank Company in 1995, and the tank was upgraded by Weston Solutions, Inc. in 2009.

3. Tank Foundation The tank rests on a concrete ringwall. The tank does not have a cathodic protection system. The tank has a liner under the bottom to contain any bottom leakage. The tank has Tracer Tightness probes as bottom leak detection. Tracer Tightness probes were installed (unknown date) through the ringwall and liner to test for any bottom leakage. The liner under the tank bottom is most likely not sealed to the liner and may not contain any bottom leakage. The Tracer Tightness probe near the manhole between the receipt line and issue line was inspected, and fuel was observed from the probe. The chime in the area of this probe has fuel wicking through the bottom-to-ringwall sealant. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. The tank bottom-to-ringwall sealant was inspected; it is not in satisfactory condition. A shell settlement survey was performed during the inspection in accordance with Appendix B of API Standard 653; it is in satisfactory condition. Settlement results are listed in Appendix A.

4. Tank Bottom The bottom (annular ring and rectangular plates) is constructed of A-36 carbon steel material. The cone-down tank bottom consists of a butt-welded annular ring fillet-welded to the shell and to the interior rectangular shaped lap-welded inner plates. The projection of the bottom plate beyond the outside toe of the shell-to-bottom weld between the receipt line and issue line is less than the minimum requirement of 3/8-inch (measured zero inches). The shell-to-bottom weld and area is of the highest potential for catastrophic failure. The bottom has a thin film epoxy coating system. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The bottom coating is in satisfactory condition. The bottom was scanned (approximately 95%) for underside corrosion using magnetic flux leakage (MFL) technology. The MFE 2412 Mark II unit was used for the MFL floor scan. The MFL scan did not reveal any significant underside corrosion. The bottom has no significant stockside (top side) pitting. The general thickness of each bottom plate was measured using ultrasonic technology. The bottom plate butt-welds, shell-to-bottom weld, attachment welds, piping supports, and support pads were visually examined. The visual examination of the welds for defects was extremely limited because the welds were coated. The bottom service life is greater than 30 years under current conditions. The bottom service life evaluation is shown in Appendix A. Twelve (12) lap-welded pipe support pads on the bottom do not have the required weld spacing of 2 inches as required by API standards. The floating roof anti-rotation anchor support pad is not at least six (6) inches with rounded corners.

5. Tank Shell The shell is constructed of A-36 carbon steel material. The shell is a cylindrical design, butt-welded together, consisting of five (5) courses. The shell interior and exterior have a thin film epoxy coating system. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The exterior and interior of the shell is in satisfactory condition. The shell was evaluated for remaining metal thickness utilizing ultrasonic technology. The ultrasonic thickness measurements and thickness measurement locations (TML) are listed in the Shell Plate Thickness Measurements table in Appendix A. A shell service life evaluation performed on all shell courses shows the shell has a remaining life of greater than 30 years under current conditions. The shell service life evaluation is shown in the Shell Service Life Evaluation table in Appendix A. Roundness, plumbness, peaking, and banding of the shell are acceptable. The tank appears to be stable and does not appear to be in danger of overturning or buckling due to high winds or seismic conditions. The weld spacing between two (2) anchor chairs and the manhole reinforcement is less than the minimum requirement of API standards. The weld spacing between circumferential stairway tread and the shell horizontal weld at three (3) locations is less than the minimum requirement of API standards. The weld spacing between circumferential stairway tread and the anchor chair is less than the minimum requirement of API standards.

6. Tank Floating Roof The tank is equipped with an internal floating roof. The floating roof is a full contact, aluminum honeycomb floating pan. The roof seals and opening gaskets were inspected for tears and deterioration. The replacement of the floating roof seals was part of this task order. The annular space between the floating roof and the shell was satisfactory.

7. Tank Fixed Roof The fixed roof is a supported cone roof constructed of A-36 carbon steel material.

The fixed roof has an epoxy coating system on the interior and exterior. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The topside coating has severely deteriorated and is beyond useful life. The roof was covered with vegetation. The fixed roof was evaluated for remaining metal thickness using ultrasonic technology. The ultrasonic thickness measurements and ultrasonic thickness locations (TML) are listed in the Fixed Roof Plate Thickness Measurements table in Appendix C.

8. Tank Appurtenances

a. Water Draw‐Off System

1) Water Draw-Off Line: The water draw-off piping consists of 3/4-inch threaded carbon steel piping. The line has a ball valve at the shell. The internal piping extends into the sump.

2) Product Saver Tank: The product saver tank (PST) is constructed of stainless steel. The PST is not grounded. The PST discharges water to a product recovery tank via a 2-inch line.

b. Low Suction System The tank is equipped with a low suction line. The system composes of 2-inch carbon steel interior piping, 2-inch shell nozzle, 2-inch ball valve, and reduces up to a 4-inch line that ties into the 16-inch suction line.

c. Issue Line The 16-inch issue line is carbon steel. The issue line is not resting on any of the internal pipe supports. Shell deformation was noted around the reinforcement.

The internal pipe supports are not adjustable. The line is protected from overpressure with a thermal relief system. The thermal relief system consists of 1-inch threaded carbon steel piping, flanges, and fittings. The thermal relief system has sight glass flow indicators and do not have a test TEE for the thermal relief valves. The flanges on the thermal relief line have coating failure and minor corrosion.

d. Receipt Line The 8-inch receipt line is carbon steel. The line has a diffuser inside the tank. The diffuser is not resting on the interior pipe supports (no deformation of the shell was noted). The internal pipe supports are not adjustable. The line is protected from overpressure with a thermal relief system. The thermal relief system consists of 1-inch threaded carbon steel piping, flanges, and fittings. The thermal relief system has sight glass flow indicators and do not have a test TEE for the thermal relief valves. The flanges on the thermal relief line have coating failure and minor corrosion.

e. Automatic Tank Gauging (Fuel Level) The tank is equipped with an ENRAF system for electronic fuel level gauging.

The system is installed in an 8-inch stilling well. The system is mounted on top of the manhole cover of the internal ladder access hatch. This stilling well is part of the internal ladder and is only slotted at the bottom. This stilling well is shared with the VITO system. This stilling well is also used for manual gauging and fuel sampling. The ENRAF probe is entangled with the VITO cable.

f. Automatic Tank Gauging (Water Level) The tank is equipped with an ENRAF VITO system for electronic water level gauging. The VITO water probe is not mounted on a designated stilling well that is located near the sump.

g. Mechanical Tank Gauging The tank is equipped with a SHAND&JURS mechanical tape level gauge for mechanical fuel level gauging. The tape of the system broke from the floating roof. The system is in functional condition.

h. Tank Sampling\Manual Gauging The tank is not equipped with a separate stilling well for sampling and manual gauging. The tank is sampled and manually gauged through the access cover of the ENRAF system. Sampling and manual gauging through the hatch without retracting the ENRAF float could damage the system. The stilling well is not slotted.

i. Level Alarms\High Level Shut‐Off The ENRAF system provides low, low-low, high, and high-high level alarms. The tank does have independent low, low-low, high, and high-high level alarms.

The low level alarm assembly consists of 1-inch threaded carbon steel piping.

The low level alarm assembly circuit has failed coating and corrosion on the flanges, piping, valves, and float chamber. The float chamber has inactive corrosion that measured 20-30 mils in depth.

The high level alarm assembly and high level shut-off assembly are accessible from the circumferential stairway without a platform. The piping consists of 1-inch threaded carbon steel piping. The assemblies do not have piping extending to the product saver tank. The flanges and valves of the high level alarm assembly are heavily corroded. The high level shut-off assembly piping has coating failure and minor corrosion.

j. Ladder and Platforms The tank’s fixed roof is accessible by a circumferential stairway mounted on the shell of the tank. The circumferential stairway has a platform for the upper manhole. The floating roof is accessible by an internal ladder through a 36-inch manhole on the fixed roof. Access to the internal ladder cannot be achieved because the ENRAF and VITO systems are mounted on top of the access cover.

The first step of the circumferential stairway is 18-1/2 inches high from the grade of the secondary containment floor. The circumferential stairway treads have coating failure and corrosion.

k. Grounding The tank has four (4) grounding straps around the circumference of the tank.

The tank grounding cables are bolted to support pads on the shell.

l. Anchoring The tank has an eight (8) anchor chairs around the circumference of the tank.

The vertical members of the anchor chairs are not notched at the shell (top and bottom).

9. Tank Piping System Fuel is received from bulk storage and issued to trucks and hydrant system.

10. Fire Protection System The fire department provides fire protection. The tank has a fire suppression system that is accessible adjacent and outside of the fuel farm. A fire hydrant is within 30 feet of the fire suppression access outside of the fuel farm.

11. Cathodic Protection The tank bottom does not have a cathodic protection system.

12. Coatings The bottom has a thin film epoxy coating system. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The bottom coating is in satisfactory condition.

The shell interior and exterior have a thin film epoxy coating system. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The exterior and interior of the shell is in satisfactory condition.

The fixed roof has an epoxy coating system on the interior and exterior. The coating was inspected for disbonding, adhesion, deterioration, and discoloration. The topside coating has severely deteriorated and is beyond useful life. The roof was covered with vegetation.

The bolt and nut of the anchor chairs has coating failure and corrosion. The low level alarm assembly circuit has failed coating and corrosion on the flanges, piping, valves, and float chamber. The float chamber has inactive corrosion that measured 20-30 mils in depth. The high level shut-off assembly piping has coating failure and minor corrosion. The fixed roof has several areas indicating standing water and several areas of failed coating. The entire roof has vegetation growth. The coating appears to have expired. The circumferential stairway treads have coating failure and corrosion. The roof circulation vents/inspection hatches have moderate corrosion and coating failure. The roof manhole and hardware have heavy corrosion and coating failure. The 24-inch center roof vent and hardware have minor corrosion and coating failure. The 6-inch blanked nozzle and hardware on the fixed roof have heavy corrosion and coating failure.

C. FINDINGS AND RECOMMENDATIONS

The following information identifies the significant findings found during the tank inspection:

1. Mandatory Mandatory findings include repairs required that provide cause for the tank to remain out of service if not accomplished. Such repairs are critical to the structural or hydraulic integrity of the tank (e.g. bottom or shell repairs).

a. Bottom Plate Projection Past Shell OBSERVATION: The projection of the bottom plate beyond the outside toe of the shell-to-bottom weld between the receipt line and issue line is less than the minimum requirement of 3/8-inch (measured zero inches). The shell-to-bottom weld and area is of the highest potential for catastrophic failure. The tank should not be placed back into service until this deficiency is corrected. Note:

API Standard 650 Sections 5.1.5.6 and 5.1.5.7 RECOMMENDATION: Replace the butt-welded annular ring between the receipt line and issue line (35 LF) in accordance with API Standard 653 Section

12.3.

b. Fuel in Intestinal Space Under Bottom OBSERVATION: The tank has Tracer Tightness probes through the ringwall for bottom leak detection. The bottom does not have cathodic protection, but does have a liner underneath. The probe near the manhole between the receipt line and issue line was inspected, and fuel was observed from the probe. The chime in the area of this probe has fuel wicking through the bottom-to-ringwall sealant. The bottom was MFE scanned and no underside corrosion was found. The bottom welds were inspected for any obvious defects for potential source of fuel underneath the bottom. The welds were coated and no obvious weld defects were found. The fuel under the tank

24-27 Drawings ED.03 and ED.04, and AW 78-24-27 Drawing D.02 Detail 1, UFGS 09 97 13.17, API Standard 653 Sections 9.9 and 9.10.2, and API Standard 650 Section 5.7 RECOMMENDATION: At a minimum if bottom is not to be replaced, conduct non-destructive testing (helium, magnetic particle, and/or dye penetrant testing) of all bottom lap-welds to locate potential fuel source under tank bottom. Remove the contaminated sand under the bottom. Replace the Tracer Tightness probes with bottom leak detection for non-elevated tank foundation in accordance with AW 78-24-27 Drawing D.02 Detail 1. Install cathodic protection in accordance with UFC 3-460-01 Sections 2-13.1 and 8-8.5, and 12-3.3 and AW 78-24-27 Drawings ED.03 and ED.04. Blast and recoat bottom in accordance with UFGS 09 97 13.17. Modify any shell nozzle that does not meet the minimum weld spacing requirements of API Standard 650 Section

5.7 in accordance with API Standard 653 Section 9.9, if the bottom is

c. Inadequate Bottom Support Pad Weld Spacing OBSERVATION: Twelve (12) lap-welded pipe support pads on the bottom do not have the required weld spacing of 2 inches as required by API standards.

Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to meet the minimum

examination by certified ASNT-TC-1A technicians of the affected welds not meeting the minimum weld spacing requirements of API standards. Note:

inspections.

d. Floating Roof Anti‐Rotation Support Pad OBSERVATION: The floating roof anti-rotation anchor support pad is not at least six (6) inches with rounded corners. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if

examination by certified ASNT-TC-1A technicians of the affected welds not meeting the minimum weld spacing requirements of API standards. Note:

e. Issue Line (Internal) OBSERVATION: The 16-inch issue line is not resting on any of the internal pipe supports. The issue line extends to the sump. Shell deformation was noted around the reinforcement. Magnetic particle (MT) examination should be performed on the nozzle and reinforcement welds after the pipe is properly

D.08 Detail 6 RECOMMENDATION: Install shims as a temporary solution to support the piping prior to placing the tank back into service. Conduct a pneumatic pressure test between the tank shell and the reinforcement plate in accordance with API Standard 650 Section 7.3.4.

f. Receipt Line (Internal) OBSERVATION: The 8-inch receipt line is not resting on any of the internal pipe supports. Magnetic particle (MT) examination should be performed on the nozzle and reinforcement welds after the pipe is properly supported and prior to placing the tank back into service. Note: The internal pipe supports are not adjustable.

CODE REFERENCE:

RECOMMENDATION:

g. Inadequate Manhole Reinforcement to Anchor Chair Weld Spacing OBSERVATION: The weld spacing between two (2) anchor chairs and the manhole reinforcement is less than the minimum requirement of API standards.

Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to meet the minimum

the affected welds prior to placing the tank back into service in the event of any

h. Inadequate Circumferential Stairway Tread to Horizontal Shell Weld Spacing OBSERVATION: The weld spacing between circumferential stairway tread and the shell horizontal weld at three (3) locations is less than the minimum requirement of API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not

the affected welds prior to placing the tank back into service in the event of any

i. Inadequate Circumferential Stairway Tread to Anchor Chair Weld Spacing OBSERVATION: The weld spacing between circumferential stairway tread and the anchor chair is less than the minimum requirement of API standards. Magnetic particle (MT) examination should be performed on the affected welds prior to placing the tank back into service, if not repaired to meet the minimum weld

the affected welds prior to placing the tank back into service in the event of any

date of inspection (e.g. spot coatings, drainage improvement, calibration, mechanical gauge repairs, grouting, etc.).

a. Secondary Containment Hairline Cracks OBSERVATION: The secondary containment may not contain any spilled product from spilling into the environment due to hairline cracks. It is not known if the secondary containment has a liner underneath the concrete.

CODE REFERENCE: 40 CFR 112.7(c); 40 CFR 112.8(c)(2), 40 CFR 112.12(c)(2), 40 CFR 112.1(b) RECOMMENDATION: Repair all hairline cracks and chips in the foundation by grinding in a V-shape pattern with at least ¼-inch width at the surface and a depth of at least ¼-inch and sealing with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

b. Bottom‐To‐Ringwall Sealant OBSERVATION: The sealant between the tank bottom and ringwall has failed in several locations. The failed areas were due to improper application and inadequate thickness. Rain water was observed entering under the bottom through the deteriorated sealant.

the floor and ringwall by removing and re-sealing with a two-component UV and jet fuel-resistant polysulfide sealant. The sealant shall conform to ASTM C 920 and shall be non-sag, Type M, Class 25 Thiokol T-2235M industrial polysulfide sealant manufactured by Polyspec, or an approved equivalent.

c. Ground Strap PVC Sleeve Sealant Though Secondary Containment Floor OBSERVATION: The PVC sleeves of the ground straps through the secondary containment floor are not sealed.

CODE REFERENCE: 40 CFR 112.7(c); 40 CFR 112.8(c)(2), 40 CFR 112.12(c)(2), 40 CFR 112.1(b)

RECOMMENDATION:

d. Mechanical Tape Level Gauge OBSERVATION: The SHAND&JURS mechanical tape level gauge (MTG) is not functional. The tape broke free from the floating roof. The bump check of the MTG failed. The MTG reads 54’ 7-1/2”.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (o) and AW 78-24-27 Drawing D.07 Detail 1

e. Anchor Chair Coating Failure and Corrosion OBSERVATION: The bolt and nut of the anchor chairs has coating failure and corrosion.

8)

f. Issue Line Thermal Relief Line Coating Failure and Corrosion OBSERVATION: The flanges on the thermal relief line of the issue line have

issue line.

g. Product Saver Tank Grounding OBSERVATION: The product save tank is not grounded.

h. Independent Low Level Alarm Coating Failure and Corrosion OBSERVATION: The low level alarm assembly circuit has failed coating and corrosion on the flanges, piping, valves, and float chamber. The float chamber has inactive corrosion that measured 20-30 mils in depth.

alarm components.

i. Circumferential Stairway Base OBSERVATION: The first step of the circumferential stairway is 18-1/2 inches high from the grade of the secondary containment floor.

floor and the circumferential stairs to meet the tread rise and run requirements of OSHA 29 CFR 1910.25.

j. Independent High Level Alarm Coating Failure and Corrosion OBSERVATION: The flanges and valves of the high level alarm assembly are heavily corroded.

alarm components.

k. High Level Shut‐Off Float Assembly Coating Failure and Corrosion OBSERVATION: The high level shut-off float assembly piping has coating failure and minor corrosion.

assembly.

l. Shell and Chime Vegetation Growth OBSERVATION: The shell and chime have vegetation growth which will eventually breakdown the coating.

vegetation growth.

m. Manhole Davit Arms OBSERVATION: Both manways do not have davit arms as required by API standards.

CODE REFERENCE: AW 78-24-27 Drawing D.10 Detail 3 and API Standard 650 Section 5.8.3.5 RECOMMENDATION: Install davit arms in accordance with AW 78-24-27 Drawing D.10 Detail 3.

n. Receipt Line Thermal Relief Line Coating Failure and Corrosion OBSERVATION: The flanges on the thermal relief line of the receipt line have

receipt line.

o. High Level Shut‐Off Control Valve OBSERVATION: The high level shut-off control valve is aluminum, which is low melting material.

either a new stainless steel or carbon steel valve.

maintain NEC Class I Division 2.

q. Fixed Roof Coating Failure and Corrosion OBSERVATION: The fixed roof has several areas indicating standing water and many areas of failed coating. The entire roof has vegetation growth. The vegetation growth is covering the blistered coating. The coating system has expired.

r. Circumferential Stairway Coating Failure and Corrosion OBSERVATION: The circumferential stairway treads have coating failure and corrosion. (QTY 20 LF)

treads.

s. Roof Circulation Vent/Inspection Hatch Coating Failure and Corrosion OBSERVATION: The roof circulation vents/inspection hatches have moderate corrosion and coating failure.

t. Roof Manhole Bonding Strap OBSERVATION: The roof manhole on the fixed roof has a broken bonding strap.

78-24-27 Drawing D.09 Detail 3.

u. Roof Manhole Configuration OBSERVATION: The roof manhole and hardware have heavy corrosion and coating failure. The manhole cover is warped and allows water intrusion onto the floating roof. The sealant around the stilling well penetration on the manhole cover allows water intrusion onto the floating roof.

well penetration, and seal the manhole cover until a permanent repair is afforded.

v. Center Roof Vent Coating Failure and Corrosion OBSERVATION: The 24-inch center roof vent and hardware have minor corrosion and coating failure.

w. Roof Blanked Nozzle Coating Failure and Corrosion OBSERVATION: The 6-inch blanked nozzle and hardware on the fixed roof have heavy corrosion and coating failure.

x. Fire Diamond Labeling OBSERVATION: The tank does not have a fire diamond label.

y. Sample Gauge Hold‐Off Distance Labeling OBSERVATION: A hold-off distance is not stenciled on the roof adjacent to the sample location.

hatch on the fixed roof.

z. Facility ID Labeling OBSERVATION: The tank does not have a facility ID label (e.g. 4310) on the shell.

with DoD Tank Standards (UFC 3-460-01, UFC 3-460-03, AW 78-24-27) or other applicable criteria.