Attachment J.3 Fac 3473 - Insp Report - Oct 2017.pdf

US Army Corps of Engineers Omaha District

API 653 Out-of-Service Inspection Report

Andrews Air Force Base, Morningside, Maryland Facility 3473

Tank 73

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

USACE POL-MCX

22 February 2017

API 653 Out-of-Service Inspection Report Andrews Air Force Base – Morningside, Maryland

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

THIS INSPECTION

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES

GENERAL TANK INFORMATION

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

3. Previous Repairs

4. Future Projects

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Tank Foundation

3. Tank Shell

4. Tank Appurtenances

5. Tank Coating

6. Tank Piping System

7. Fire Protection System

8. Secondary Containment

C. FINDINGS AND RECOMMENDATIONS

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

2. SIGNIFICANT FINDINGS per API 653, NFPA 30 or CFRs

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

4. REPAIRS to Fully Comply with API 653, or UFC 3-460-01 and/or AW 78-24-27 Guidance

APPENDIX A: SUB-CONSULTANT REPORTS

API 653 OUT-OF-SERVICE INSPECTION REPORT

APPENDIX B: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

AFFF Aqueous Firefighting Foam

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

CMU Concrete Masonry Unit

CP Cathodic Protection

DFT Dry Film Thickness

FAC Facility

HLA High Level Alarm

HHLA High-High Level Alarm

IFR Internal Floating Roof

LCV Level Control Valve

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

NPT National Pipe Taper Thread

PSI Pounds per Square Inch

PT Penetrant Testing

PTFE Polytetrafluoroethylene (e.g., Teflon)

P/V Pressure/Vacuum

RP Recommended Practice

TRV Thermal Relief Valve

UFC Unified Facilities Criteria

UFGS Unified Facilities Guide Specifications

GENERAL SUMMARY

Austin Brockenbrough & Associates, LLP (Brockenbrough) was retained by Omaha District USACE under Contract

No. W9128F-12-D-0006 Delivery Order 0036 to perform SPCC Mandated API 653 Out-of-service (internal and external) Inspection of Facility 3473 (locally known as Tank 73) at Andrews Airforce Base in Morningside, Maryland. This inspection was completed on August 5, 2017 in accordance with API Standard 653, “Tank

Inspection, Repair, Alteration, and Reconstruction,” and the referenced contract. The out-of-service inspection was performed by Brockenbrough and our sub-consultant, InterSpec, LLC (InterSpec).

Facility 3473, locally known as Tank 73, is a 31-foot and 0-inch diameter by 41-foot and 3-inch tall, single wall, vertical, field erected tank with a nominal storage capacity of 5,000 barrels of jet fuel (F-24). The tank erectors nameplate indicates a date of construction of 2005. Table 3-1 of the Facility’s 2011 SPCC plan indicates a date of construction of 2006. The tank’s aluminum internal floating pan was manufactured by Petrex. Secondary containment is provided by concrete dike walls and basin, which is shared with Facility 3474.

There are no Mandatory Repairs noted that need immediate attention. Details of tank construction and appurtenances are included in the Tank Information Table in Section ‘B’. Additional noted deficiencies are discussed in more detail in Section ‘C’, and should be addressed in a timely manner. Our sub-consultant’s report is included in Appendix ‘A’. Additional photographs are included in Appendix ‘B’.

The next API Standard 653 In-Service (visual external) Inspection should be performed by October 2022. The next ultrasonic thickness inspection of the shell should be performed by October 2032. While the current UFC 3-460-03 requires out-of-service inspection to occur every 10 years of service, an upcoming revision allows the frequency to be extended as determined by a certified API 653 tank inspector. While the corrosion rate calculations indicate the inspection-interval could be extended to 30 years, the presence of stainless steel piping on the interior of the tank increases the risk of concentrated internal corrosion. Therefore, the next API Standard 653 Out-Of-Service

(internal and external) Inspection should be performed by October 2037. This inspection should include an examination of the tank bottom by magnetic flux leakage (MFL or MFE) technology, and a thorough code compliance evaluation.

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S. Air Force

Location Joint Base Andrews

Facility Number 3473

Tank Number Tank 73

State / Country Maryland / U.S.A.

City Morningside

Inspection Date October 5, 2017

Tank Manufacturer Witherup Fabrication and Erection, Inc.

Design Standard API 650

Date of Construction 2005 (per nameplate)

Tank Contents Jet fuel (F-24)

Tank Serial Number 09654

Tank Diameter 31’-0”

Shell Height 41’-3”

Product Height 37’-6 3/4” (limited by overflow)

Tank Capacity 5,000 bbl nominal. (4,500 useable)

Foundation 18” concrete ring wall.

Construction/Material

Bottom 5/16-inch, lap welded, carbon steel plate, unknown grade, cone-down.

Shell Five butt-welded shell courses 1/4-inch plate /A36 Mod.

Floating Roof Petrex aluminum honeycomb pan.

Fixed Roof Partially supported cone roof. 1/4-inch plate / carbon steel.

Cathodic Protection Impressed current.

Interior Coating System Interior 100% coated, likely epoxy. Applied in 2006

Exterior Coating System Epoxy/polyurethane assumed. Applied in 2006

Level Gauging 6-inch well with Enraf ATG and Vito water probe, 8-inch manual gauge ladder well, Shand and Jurs Autogauge.

Overfill Protection Independent high and high-high level alarms, float operated LCV.

Piping Receipt 8” Carbon Steel

Issue 12” Carbon Steel Water Draw-off 1” Carbon and Stainless Steel

Level Alarms Independent high, high-high, and low level alarms; ATG Alarms.

Cleaning, Inspection, Repair In-service inspection in 2015.

RPB/Leak Detection Under bottom liner, 3 leak detection ports, 1 leak detection well.

Stairs/Ladders Circumferential stairway w/lower, middle, and upper landings. Internal ladder.

Manholes Two 36-inch lower shell manholes. One 36-inch upper shell manhole. One 36-inch roof manhole.

Venting/Vapor Controls Center roof vent, 4 roof perimeter vent/inspection hatches, 4 shell overflows.

PST Yes

Secondary Containment Concrete dike wall and basin shared with adjacent tank (Facility 3474).

Fire Protection System (4) fire hydrants within 300 feet.

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.

For Facility 3473 (Tank 73), an API Standard 653 Out-of‐service (internal and external) Inspection was performed, which included a shell settlement survey, a shell UT inspection, and evaluation of the of the shell plumbness and roundness. See subconsultant’s report in Appendix ‘A’ for details.

2. Site Information

On October 3 through 5, 2017 Brockenbrough performed API 653 Out-of‐service (internal and external) Inspection of Facility 3473 (Tank 73) located at Andrews Air Force Base, which is located in

Morningside, Prince George's County, Maryland. The facility is under the jurisdiction of the United

States Air Force 11th Wing, Air Force District of Washington. In 2009, Andrews Air Force Base and

Naval Air Facility Washington were merged to form Joint Base Andrews. The Base is named for

Lieutenant General Frank Maxwell Andrews (1884–1943), former Commanding General of United

States Armed Forces in the European Theater of Operations during World War II. The Base is widely known for serving as the home base of two Boeing VC-25 aircraft which have the call sign Air Force One while the President of the United States is on board. As of the 2010 census, the resident population was

2,973. The host unit at Andrews is the 11th Wing, assigned to the Air Force District of Washington. The

Wing is responsible for maintaining emergency reaction rotary-wing airlift and other National Capital

Region contingency response capabilities critical to national security, and for organizing, training, equipping and deploying combat-ready forces for Air and Space Expeditionary Forces (AEFs). The

Wing also provides installation security, services and airfield management to support the President, Vice President, other U.S. senior leaders and more than 50 tenant organizations and federal agencies.

The list of the types of aircraft that fly out of Andrews Air Force Base is extensive, as are the list of the branches of the military that fly out of Andrews Airforce Base.

3. Previous Repairs

Base personnel indicated no repairs have been performed on the tank since its construction.

4. Future Projects

Base personnel indicated there are no known future projects affecting the tank.

https://en.wikipedia.org/wiki/United_States_Air_Force https://en.wikipedia.org/wiki/United_States_Air_Force https://en.wikipedia.org/wiki/11th_Wing https://en.wikipedia.org/wiki/Air_Force_District_of_Washington https://en.wikipedia.org/wiki/Andrews_Air_Force_Base https://en.wikipedia.org/wiki/Naval_Air_Facility_Washington https://en.wikipedia.org/wiki/Lieutenant_General https://en.wikipedia.org/wiki/Frank_Maxwell_Andrews https://en.wikipedia.org/wiki/United_States_Armed_Forces https://en.wikipedia.org/wiki/United_States_Armed_Forces https://en.wikipedia.org/wiki/European_Theater_of_Operations https://en.wikipedia.org/wiki/World_War_II https://en.wikipedia.org/wiki/Boeing_VC-25 https://en.wikipedia.org/wiki/Aircraft https://en.wikipedia.org/wiki/Air_Force_One https://en.wikipedia.org/wiki/President_of_the_United_States https://en.wikipedia.org/wiki/2010_United_States_Census https://en.wikipedia.org/wiki/Population https://en.wikipedia.org/wiki/11th_Wing https://en.wikipedia.org/wiki/Air_Force_District_of_Washington

B. TANK INSPECTION COMMENTS

1. Tank Construction

Facility 3473 is a nominal 5,000 bbl, 31‐foot diameter by 41-foot and 3-inch tall, Jet Fuel (F‐24) aboveground vertical storage tank. The tank erectors nameplate indicates the tank was constructed in

2005. Table 3-1 of the Facility’s SPCC Plan indicates a date of construction of 2006. The tank has a cone down bottom, with a center sump, a Petrex aluminum honeycomb internal floating pan, and cone roof.

2. Tank Foundation

The tank rests on an 18-inch tall ringwall foundation. Three leak detection tell-tale pipes project out of the ringwall. There is also a leak detection well cast into a projection of the concrete ringwall. The leak detection pipes and well, along with the year of construction, suggest there is a liner under the tank bottom. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. Approximately one-quarter of the tank bottom to foundation seal has failed. A shell settlement (foundation) survey was performed during the inspection in accordance with Appendix B of API Standard 653. The shell settlement evaluation indicates no significant shell settlement and the elevation of the bottom of the shell is within tolerance for new construction. No cracks were noted in the ringwall. The measured out of plane deflection does not indicate significant settlement. Therefore, no action is required. The measurements and analysis are recorded in our sub-consultant’s report.

3. Tank Shell

The vertical and cylindrical shell consists of five butt‐welded courses. The exterior of the shell was visually inspected and evaluated for plumbness, roundness, peaking, and banding. No significant peaking or banding of the shell seams was noted, the shape of the shell appears to be within the allowable tolerances of API Standard 653. The coating was evaluated for deterioration. The ultrasonic thickness measurements of the shell and calculations included in Appendix ‘A’ indicate the shell has more than 30 years of remaining life. API 653 recommends ultrasonic thickness measurements of the shell be taken at least every 15 years.

4. Tank Appurtenances

a. Tank Roof

The tank’s steel, lap welded cone roof shows sign of water ponding around the perimeter. There are only eight rafters. The rafters are spaced more than 12 feet apart as measured on the circumference of the perimeter of the roof. As early as 1996, API 650 required the rafter spacing at the perimeter of the tank roof to be no greater than 75 inches apart. Earlier API requirements may have been more stringent. Later editions of API 650, paragraph 5.10.4.4 increased the maximum allowable circumferential spacing to 84 inches.

b. Internal Floating Pan

The tank’s aluminum honeycomb internal floating pan was manufactured by Petrex. The floating pan perimeter seal is a double foam log. The foam log primary seal is cracked, several areas are saturated with fuel. One area of the foam log primary seal located near the internal ladder was noted to be sagging and dripping fuel.

c. Venting

The tank has a 26-inch diameter roof center vent, 4 perimeter vent inspection hatches and 4 shell overflow/vents. The vents are covered with insect screen. API 650 does not allow insect screen on vents as this significantly reduces the ventilation capacity and is subject to clogging.

d. Gauging

The tank’s Enraf ATG is installed in a 6-inch flanged aluminum stilling well suspended from an 8-inch carbon steel roof nozzle with an internal flange just under the roof. A Vito water probe is installed in the same stilling well as the ATG. Manual gauging may be performed through the 8-inch ladder stilling well/side rail under the roof manhole cover, which is equipped with a gauge hatch.

The internal ladder side rails are securely fastened to neck of the roof manhole by U-bolts. The manual and ATG stilling wells are also welded to their bottom guides, which are bolted rigidly to their mounting plates, which in turn are welded to the tank bottom. API 650 does not allow columns to be fastened to both the tank roof and the tank bottom. The bolt holes are not slotted, however slotted bolt holes and their length are included in USACE Standard Design AW 78-24-27 for adjusting the datum plate elevation only. While perhaps not obvious, the intent of the detail included in the USACE Standard Design AW 78-24-27 in effect at the time was that the guides touch but not be welded to the stilling wells, so that the datum plates, which were to be welded to the bolted guides, could be adjusted using the slotted bolt holes. There is no standard in API 650 for the design of slotted bolt holes to allow movement of the roof and bottom connected by a column.

The 2010 release of the DoD Standard Design AW 78-24-27 clarified the detail.

e. Level Alarms

The tank has independent (shell mounted) high, high-high, and low level alarms. The high level alarms are accessible from the circumferential stairway intermediate landing. The alarms are plumbed to allow testing when the receipt piping is pressurized.

f. Stairs, Landings and Ladders

The tank’s steel cone roof is accessible by a circumferential stairway mounted on the shell of the tank. A concrete landing with radial approach steps provides access to the bottom of the stairway.

The circumferential stairway incudes a lower landing for accessing the upper shell manhole and floating pan at high leg position. The circumferential stairway also includes an intermediate landing for accessing the high level alarms and controls.

g. Grounding and Bonding

There are four grounding cables bolted to couplings, which are welded to the shell.

h. Shell Manholes

The tank has two lower 36-inch shell manholes and one upper 36-inch shell manhole. The shell manhole covers are hinged.

5. Tank Coating

The interior and exterior of the shell are coated. There is coating failure and corrosion on the receipt and issue DBB valves, TRV valves and their connecting flanges, and on the roof perimeter vent/inspection hatches at the roof penetration frames, hinges and bottoms of the covers.

6. Tank Piping System

Fuel is received into the tank through 8-inch carbon steel piping via underground piping from the adjacent pumphouse, which receives fuel via underground pipeline from the bulk tanks in the southeast tank farm, and is issued from the tank through 12-inch carbon steel underground piping through the adjacent pumphouse to a hydrant system.

7. Fire Protection System

There are four fire hydrants within 300 feet of the tank.

8. Secondary Containment

A concrete dike and basin provide secondary containment, which is shared with the sister tank (Facility

3474). The distance of the swale from the tank varies from 6 to 10 feet from the tank. Filling the secondary containment drainage sump with water and holding for more than an hour while observing a stable water level in the sump (hydrostatic testing) indicates the integrity of the drain valve, sump, and drain piping is acceptable. The receipt piping runs over the swale. NFPA 30 paragraph 22.11.2.1 requires the dike basin to be sloped away from the tank for a distance of 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 a distance of 50 feet.

The expansion joints between the dike basin and the foundation as well as between the dike basin and the dike walls have failed.

The grounding cables penetrate the concrete ringwall foundation through unsealed pipe. The three (3) leak detection tell-tale pipes also penetrate the concrete ringwall through unsealed penetrations.

The volume of the secondary containment is sufficient to hold the contents of the tank full to the bottom of the overflow as required by NFPA 30, plus approximately 12 inches of freeboard. Guidance for the design of new tanks included in UFC 3-460-01 includes only 12 inches of freeboard.

C. FINDINGS AND RECOMMENDATIONS

Tank Facility 3473 was found to be in generally good condition. The tank is fully serviceable, with no mandatory deficiencies that would require immediate removal of the tank from service. However, there were several items observed, that are not in full compliance 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. SIGNIFICANT FINDINGS per API 653, NFPA 30 or CFRs

The following information identifies the significant findings found during the tank inspection, and includes repair recommendations.

a. Provide Stilling Wells

OBSERVATION: The internal ladder side rail well, which is accessible through a roof manhole cover provides the only means of manual gauging, is not slotted above 5-foot level, and does not have a floating plug retriever. The Enraf ATG and Vito Water/Temperature Probe share a 6-inch well located near the perimeter of the tank. The 6-inch ATG/Water Probe well transitions to stainless steel just under the roof and is not slotted above the 5-foot level. The stainless steel may result in galvanic corrosion under any interior coating flaws, if water is present. If the well were made of aluminum it could provide some passive cathodic protection.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes an 8-inch aluminum full length slotted stilling well for the ATG and a 6-inch aluminum stilling well near the tank center for the Vito Water/Temperature probe.

RECOMMENDATION: Provide a 10-inch roof nozzle with an 8-inch aluminum full length slotted stilling well for the ATG and a separate 8-inch roof nozzle with a 6-inch aluminum stilling well in or near the bottom sump for the Vito Water/Temperature probe. Eliminate the stainless steel stilling well. Full length slot the ladder well.

ATG/Water

Probe Well

ATG/Water

Probe Well

Internal Ladder Access Manhole

b. Modify Stilling Well Guides

OBSERVATION: The 6-inch combination ATG and Vito Water Probe well is bolted to the tank bottom, as well as attached to the tank roof. In addition, the internal ladder is attached to the tank roof manhole neck as well as bolted to its bottom end guides, which are welded to the tank bottom.

REFERENCE: API 650 paragraph 5.10.4.7.d) requires columns to be free to move vertically relative to the tank bottom. Guidance for the design of new storage tanks provided in DoD Standard Design

AW 78-24-27 allows stilling wells and ladders to be free to move vertically.

RECOMMENDATION: Loosen the U-bolts attaching the internal ladder to the roof manhole neck, and double nut the U-bolts to the manhole neck. If the well is not demolished, remove the welds attaching the combination ATG and Vito Water Probe well to the bottom guides.

c. Provide OSHA Compliant Ladder Access Hatch

OBSERVATION: The internal ladder access round roof manhole provides less than 28 inches of clearance on the climbing side of the ladder, does not have a deflector plate, is not gasketed or bolted, does not have a rain lip, and allows rain water to enter the tank.

REFERENCE: OSHA regulation 29 CFR 1910.27 (c) requires 30 inches of clearance on the climbing side of a ladder, or a deflector plate on the underside of the opening, set at an angle of 60 degrees from horizontal. API 650 paragraph 5.8.4 requires round roof manholes to be gasketed and bolted.

Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes a rectangular ladder access hatch with hinges and a rain lip as allowed by API 650 Paragraph 5.8.6.

RECOMMENDATION: Provide an OSHA and API compliant internal ladder access hatch.

Internal Ladder Access Hatch

ATG/Water

Probe Well

Remove these welds.

d. Remove Insect Screens

OBSERVATION: The four (4) shell overflows are covered with insect screen. Insect screen significantly reduces the ventilation capacity and is subject to clogging. However, as discussed in

Section C.4 of this report, only the overflow opposite the stairway and tank nozzles is necessary.

REFERENCE: API 650 paragraph H-5.2.2 requires vent screens with 1/2-inch openings.

RECOMMENDATION: Remove the insect screen from the shell overflow opposite the stairway and product nozzles.

e. Smooth the Interior Horizontal Welds

OBSERVATION: As observed from on top of the floating pan at high leg position, the interior horizontal welds appear to have a rougher profile and more weld spatter than allowed by the current UFGS Specification 33 56 13.13 for new construction. Rough surfaces of welds may reduce the life of the floating pan perimeter seals and the interior coating.

REFERENCE: Guidance for new construction provided in UFGS Specification 33.56.13.13 includes evaluating the finish of welds in accordance with NACE using a visual comparator for reference.

RECOMMENDATION: When the interior coating is replaced grind the interior horizontal weld surfaces smooth and remove weld splatter.

Overflow

f. Modify the Roof Support Structure

OBSERVATION: The tank’s steel, lap welded, cone roof shows sign of water ponding around the perimeter. There are only eight rafters. The rafters are spaced more than 12 feet apart at the perimeter of the roof.

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

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

g. Provide Conduit and Connector

OBSERVATION: A conduit, with wiring connections inside an electrical junction box, is not properly connected to the junction box, but is only butted up against the box and caulked.

REFERENCE: NFPA 70 paragraph 500.5(B)(2)(1) and guidance for new construction provided in UFC

3-460-01 Paragraph 2-12.1.1 considers all outdoor locations within 5 feet of fuel storage tanks to be Class 1 Division 2. NFPA 70 paragraph 500.7 requires electrical equipment that is not intrinsically Safe and used in Class I Division 2 locations to be explosion proof.

RECOMMENDATION: Provide an explosion proof conduit connection to the electrical junction box.

h. Replace Floating Pan Penetration and Perimeter Seals

OBSERVATION: The internal floating pan’s original penetration seals are deteriorated. The internal floating pan’s original double wiper perimeter foam log seal is showing signs of wear. An area of the primary perimeter foam log seal near the internal ladder is starting to sag and retain fuel.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 and

UFGS Specification 33 56 13.13 includes double wiper squeegee urethane perimeter seals.

RECOMMENDATION: Replace the floating pan perimeter seals with urethane double wiper squeegee perimeter seals. Replace the floating pan penetration seals with urethane wiper seals.

i. Seal Secondary Containment

OBSERVATION: There are approximately 60 feet of unsealed cracks in the shared dike walls and 30 feet of unsealed cracks in the shared dike basin. Rainwater entering the concrete through the cracks may cause deterioration of the reinforcing steel and/or freeze and expand causing widening of the cracks and further deterioration. In addition, the expansion joint sealants between the dike basin and the dike wall and foundations, and 10 feet of dike basin expansion joint have failed.

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

RECOMMENDATION: Rout and seal 50 feet of unsealed cracks in the shared dike walls and 30 feet of unsealed cracks in the shared dike basin. Replace the sealants between the dike basin and the dike wall and foundations and in 10 feet of dike basin expansion joint.

j. Provide Penetration Seals

OBSERVATION: The receipt piping and the issue piping both penetrate the dike basin through pipe sleeves without any seals between the sleeves and the piping. Drawings for the dike basin and penetrations were not available at the time of the inspection to confirm if there is a liner under the concrete sealed to the piping.

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

RECOMMENDATION: If as-built drawings indicating a liner sealed to the piping under the dike basin cannot be located, the gap between the product piping and the dike basin penetration sleeves should be sealed using a modular elastomeric compression seal.

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

Recommended repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. Remove the Insect Screens

OBSERVATION: The four (4) roof perimeter vent and the four (4) shell overflows are covered with insect screen. Insect screen significantly reduces the ventilation capacity and is subject to clogging.

REFERENCE: API 650 paragraph H-5.2.2 requires vent screens with 1/2-inch openings.

RECOMMENDATION: Remove the insect screens from the perimeter vents and shell overflows.

b. Adjust Enraf Door Latches

OBSERVATION: The Enraf ATG access door latches are out of adjustment and do not properly engage the door seal so as to prevent rainwater from entering the tank.

REFERENCE: NA.

RECOMMENDATION: Adjust the Enraf access door latches so that all latches engage the door seal.

c. Repair Concrete

OBSERVATION: The concrete dike basin is spalled around the base of the dike access steps support pedestal.

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

RECOMMENDATION: Repair the concrete where it is spalled around the base of the dike access steps support pedestal.

d. Repair Tank Bottom-to-Foundation Seal

OBSERVATION: Approximately a quarter of the tank bottom to foundation seal has failed.

REFERENCE: Guidance for maintenance of fuel storage facilities provided in UFC 3-460-03 paragraph 8-4.1. B. includes monthly inspection and repair of the tank bottom to foundation seal.

RECOMMENDATION: Replace the failed areas of the tank bottom to foundation seal.

e. Provide Junction Box Gasket

OBSERVATION: A conduit junction box with a threaded cover is missing its gasket/ O-ring.

REFERENCE: NFPA 70 paragraph 500.5(B)(2)(1) and guidance for new construction provided in UFC

3-460-01 Paragraph 2-12.1.1 considers all outdoor locations within 5 feet of fuel storage tanks to be Class 1 Division 2. NFPA 70 paragraph 500.7 requires electrical equipment that is not intrinsically safe and used in Class I Division 2 locations to be explosion proof.

RECOMMENDATION: Provide a gasket/O-ring for the electrical junction box shown to ensure the electrical junction box is explosion proof.

f. Replace Grease Fitting

OBSERVATION: A grease fitting on the northwest shell manhole cover hinge shaft is broken.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes a grease fitting on shell manhole cover davits.

RECOMMENDATION: Replace a grease fitting on the northwest shell manhole cover hinge shaft.

g. Remove Vegetation

OBSERVATION: There is a small amount of vegetation growing out of the secondary containment expansion joints.

Reference: Guidance for maintenance of fuel storage facilities provided in UFC 3-460-03 paragraph 8-10.2.2 includes daily inspection of concrete secondary containment for cleanliness and removal of vegetation.

RECOMMENDATION: Continue to inspect and remove vegetation from the expansion joints of the concrete secondary containment.

h. Seal Secondary Containment

OBSERVATION: The grounding cables penetrate the concrete ringwall foundation through unsealed pipe. The three (3) leak detection tell-tale pipes also penetrate the concrete ringwall through unsealed penetrations.

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

RECOMMENDATION: Seal the grounding cables where they penetrate the concrete ringwall foundation through pipe sleeves. Seal the three (3) leak detection tell-tale pipes where they penetrate the concrete ringwall through pipe sleeves.

i. Pressure Wash Exterior

OBSERVATION: The isolated areas of the exterior of the shell and roof are covered with mold and algae, which can lead to coating failure. In addition, bird droppings were observed on the roof guardrail. API 570 paragraph 4.3.2.3.h) reads, “bird turds can also cause accelerated corrosion and unsightly stains.”

REFERENCE: Guidance for the design of new storage tanks provided in UFC 3-460-01 paragraph 8-

3.10 requires the exterior to be coated.

RECOMMENDATION: Pressure wash the exterior of the tank regularly.

j. Repair Appurtenance Coatings

OBSERVATION: There is coating failure and corrosion on the receipt and issue DBB valves, TRV valves and their connecting flanges, and on the roof perimeter vent/inspection hatches at the roof penetration frames, hinges and edges of the covers. There is coating failure on the cathodic protection conduit, underside of the roof manhole cover and on the flange; level alarm sensor mounting flanges, and underside of the center vent cover.

REFERENCE: Guidance for new construction provided in UFC 3-460-01 paragraph 8-3.9 includes coating the interior. Paragraph 8-3.10 includes coating the exterior.

RECOMMENDATION: Repair the coatings on the cathodic protection conduit, receipt and issue DBB valves; TRV valves and their connecting flanges; the roof perimeter vent/inspection hatches at the roof penetration frames, hinges, and edges of the covers; level alarm sensor mounting flanges;

underside of the roof manhole cover and on the flange; and underside of the center vent cover.

k. Replace Nuts and Bolts

OBSERVATION: The nuts and bolts on the Enraf access/mounting chamber are corroded.

REFERENCE: Guidance for the design of new storage tanks provided in UFC 3-460-01 paragraph 8-

3.10 requires the exterior to be coated.

RECOMMENDATION: Replace the bolting on the Enraf access/mounting chamber with corrosion resistant bolting.

4. REPAIRS to Fully Comply with API 653, or UFC 3-460-01 and/or AW 78-24-27 Guidance

These items represent repairs and/or upgrades that could be performed to bring the tank into full compliance with current standards, but that do not represent potential risks to system operators, equipment integrity, or the adjacent environment. Our recommendations to perform, or not to perform these repairs and/or upgrades, take into consideration the cost of the repair, the operational benefit of the repairs, the age of the tank/system, operator safety, environmental risks, and equipment integrity.

a. Modify Overflows

OBSERVATION: The tank has four (4) shell overflows measuring approximately 3 feet by 1 foot, which are covered with expanded metal and insect screen. Two of the shell overflows are located over the stairs and the receipt nozzle isolation valve. A third shell overflow is located over the issue isolation valve and the stairway radial approach steps. Fuel is received into the tank through two parallel 600 gpm filter/separators and an 8-inch nozzle.

REFERENCE: API 650 paragraph H.5.3.3 does not allow overflows to be located over stairways or tank nozzle isolation valves with limited exceptions. Guidance for new construction included in

DoD Standard Design shows only one overflow with 2 square feet of net open area on 5,000 through 30,000 bbl tanks with 8-inch receipt nozzles. The Standard Design drawings show the overflow on the side of the tank opposite the product nozzles and not over the stairway.

RECOMMENDATION: If the safety of personnel who may be on the roof or access to shell nozzle valves during an overflow event are a concern, eliminate the three shell overflows located over the circumferential stairway and/or shell nozzle isolation valves, and repair the shell at those locations.

Overflow

Stairs

Issue

Receipt

b. Modify the Receipt Piping

OBSERVATION: There is no isolation valve upstream and adjacent to the level control valve.

REFERENCE: Guidance provided in UFC 3-460-01 paragraph 7-6.3.4 and DoD Standard Design AW

78-24-27 include an isolation valve upstream and adjacent to the level control valve on new storage tanks.

RECOMMENDATION: If the ability to service the level control valve without having to drain the piping is desired, provide an isolation ball valve upstream and adjacent to the level control valve.

c. Provide Exothermic Grounding Connections

OBSERVATION: The tank’s grounding cables are bolted to couplings welded to the shell.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 Detail

2/ED.02 includes exothermic-welding the grounding cables to stainless steel grounding lugs.

RECOMMENDATION: If in addition to lightning protection, a means to reliability control stray electrical currents is desired, provide grounding lugs and exothermically welded grounding connections.

d. Modify Thermal Relief Piping

OBSERVATION: The receipt and issue thermal relief piping includes sight flow indicators. Facility personnel indicated they want to keep the sight flow indicators.

REFERENCE: Guidance for the design of new storage tanks provided in UFC 3-460-01 paragraph 9-

3.5 includes TRV piping around isolation valves; paragraph 9-3.5.1 discourages site flow indicators on thermal relief valve piping.

RECOMMENDATION: If Facility personnel agree, modify the thermal relief piping to eliminate the site flow indicators.

e. Pipe low Suction to Main Suction

OBSERVATION: The low suction nozzle is not piped to allow using the issue pumps to drain the tank in preparation for tank cleaning and entry. In theory, the location of the internal low suction piping could potentially reduce the self-cleaning action of the cone down bottom.

REFERENCE: Guidance for the design of new storage tanks provided in UFC 3-460-01 Table 8-1, Item v and DoD Standard Design AW 78-24-27 include hard piping the low suction to the main suction.

RECOMMENDATION: If the time and cost of removing the last few hundred barrels of fuel from the tank in preparation for cleaning and or maintenance is an issue, consider providing piping and valves to connect the low suction to the main suction.

Low Suction

Main Suction

f. Adjust Internal Pipe Supports

OBSERVATION: The internal issue piping is not resting on its pipe support. The internal pipe supports are adjustable. However, the tank bottom may be expected to flex downward and piping to flex upward, due to the weight of the fuel and buoyancy of the pipe, when the tank is filled, thus widening the gap between the piping and the supports.

REFERENCE: DoD Standard Design AW 78-24-27 includes internal bolted pipe supports with slotted holes for adjusting the height of the support.

RECOMMENDATION: If supporting the internal piping when the tank is empty is a concern continue to readjust the internal pipe supports whenever the tank is taken out of service for cleaning.

g. Reinstall Autogauge Tape

OBSERVATION: The Shand and Jurs autogauge tape was connected directly to the floating pan. As a result, the gauge is inoperable.

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

(Varec and Shand & Jurs) recommend attaching the tape to a float in a floating pan penetration well or to a weight resting on top of the pan, but not directly to the pan to avoid damage to the tape or gauge head in the event the pan does not descend smoothly with the fuel.

RECOMMENDATION: Consider reinstalling the autogauge tape in accordance with the manufacturer’s recommendations and instructions.

Broken Autogauge Tape Connection

Autogauge Head

h. Modify Secondary Containment

OBSERVATION: A concrete dike and basin provide secondary containment, which is shared with the sister tank (Facility 3474). The distance of the swale from the tank varies from 6 to 10 feet from the tank. The receipt piping runs over the swale.

REFERENCE: NFPA 30 paragraph 22.11.2.1 requires secondary containment 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 a distance of 50 feet.

RECOMMENDATION: If future projects include major modifications to the site, consider modifying the secondary containment to slope to the drain and away from the tank all the way to the dike wall and away from the piping.

i. Provide Low-low Level Alarm

OBSERVATION: The only shell mounted low level alarm is located below the low leg level of the floating pan and has threaded connections.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes low and low-low level alarm chambers above the low leg level of the floating pan.

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

RECOMMENDATION: If ensuring the operating level of the fuel is high enough to realize the benefit of a full contact floating pan is desired, demolish the existing low level alarm chamber, nozzles, piping, and sensors. Provide new shell mounted low and low-low level alarms at the proper levels.

Receipt piping

Issue piping

Low Level Alarm

Swale

Dike Drain

j. Reinstall Latch

OBSERVATION: The roof perimeter vent/inspection hatches have two latches each. However, one of the latches on the roof perimeter vent/inspection hatch counter clockwise of the ATG has one latch that is inoperable due to faulty installation.

Reference: Guidance for new construction provided in DoD Standard Design AW-24-27 includes roof perimeter vent/inspection hatches with two latches per hatch.

RECOMMENDATION: The next time other welded repairs are performed on the tank,reinstall the faulty latch on one of the roof perimeter vent inspection hatches so that the latch is operable.

k. Provide Grounding for the Product Saver Tank

OBSERVATION: The product saver tank stainless steel piping is isolated from the tank by the isolation flange kit on the shell nozzle isolation valve. The piping between the stainless steel product saver tank piping and the water draw-off nozzle isolation valve is carbon steel. An electric motor is mounted on the product saver tank piping, but the product saver tank is not grounded.

REFERENCE: Guidance provided in DoD Standard Design AW 78-24-27 and UFC 3-460-01 paragraph

2-12.3 include grounding for new product saver tanks. Paragraph 9-8 i) includes isolation flanges for connecting dissimilar metals.

RECOMMENDATION: If lightning protection is desired, provide a grounding system for the product saver tank. Do not bond the product saver tank to the same grounding system as that on the tank in order to maintain some degree of electrical isolation. Replace with stainless steel piping, the carbon steel piping between the stainless steel piping and the water draw-off nozzle isolation valve.

l. Replace Internal Piping

OBSERVATION: The receipt, issue, low suction and water draw-off nozzles are internal flanged and their internal piping is stainless steel. The ATG stilling well is also stainless steel. Galvanic corrosion of the interior of the tank may occur, if water is present. The issue internal piping terminates horizontally inside the tank.

REFERENCE: Guidance for the design of new storage tanks provided in DoD Standard Design AW 78-

24-27 indicates issue piping that terminates inside the tank with a turn down elbow approximately

4 inches above the tank bottom, carbon steel internal receipt, issue, low suction, and water draw-off piping, and aluminum stilling wells. Guidance for the design of new fuel facilities provided in UFC , and 3-460-01 paragraph 2-12.3.3 prohibit the bonding of dissimilar metals.

RECOMMENDATION: If water is expected inside the tank, replace the stainless steel receipt, issue, low suction and water draw-off internal piping with carbon steel per DoD Standard Design AW 78-24-

27. Replace the stainless steel stilling well with aluminum, or if 8-inch aluminum stilling wells are provided as recommended elsewhere in this report, demolish the 6-inch stainless steel stilling well.

m. Remove Stainless Steel IFR Striker Plates

OBSERVATION: The internal floating pan support leg striker plates are stainless steel and glued to the tank bottom. Galvanic corrosion of the interior of the tank may occur, if water is present and the stainless steel striker plates make contact with the pan support legs or the tank bottom.

REFERENCE: API 650 paragraph H.4.6.6 (paragraph H.4.7.4 in the 1993 and previous editions) requires that if striker plates are used, they be welded to the tank bottom. Guidance included in

UFC 3-460-01 paragraph 2-12.3.3 discourages the bonding of dissimilar metals in new storage tanks. Guidance for new construction included in UFGS Guide Specification 33 56 163.13 includes

PTFE feet on the bottoms of IFR support legs.

RECOMMENDATION: When major repairs to the internal coating are performed, remove the stainless steel IFR support leg striker plates, examine the tank bottom under the striker plates, repair the tank bottom and internal coating if indicated, and provide PTFE feet on the IFR support legs.

APPENDIX A: SUB-CONSULTANT REPORTS

API 653 OUT-OF-SERVICE INSPECTION REPORT

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ER-US AIR FORCE - ANDREWS AFB-ANDREWS AFB, MD-TANK#3473-OCTOBER/2017

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 2

General Conditions

The information referenced in this engineering report is based solely upon the area or areas agreed upon and contracted for inspection on the date of the inspection and under those present, known, same, and current conditions. This report was prepared using retrievable data from those areas that were made available and accessible during the inspection. Areas not contracted for inspection and/or made available and accessible are not included in this report.

The methods, standards and regulations used by InterSpec, LLC during the inspection and in preparing this engineering report comply with the most current and widely accepted standards and regulations in the industry, in which these standards and regulations make no representation, warranty or guarantee.

The professional opinions and recommendations stated in this report, including predictability of life, maximum length of time for re-inspection, suitability for product storage, and safe fill height are conclusive approximations and are intended to serve mainly as guidelines for obtaining the utmost in spill prevention and environmental protection. The listed recommendations may not necessarily be mandatory actions, but corrective actions that InterSpec, LLC suggests would better preserve the owners’/operators’ facility components and may contribute to a safer and more convenient operation.

Failure to comply with these could result in, but may not be limited to, reduction of service life, tank mishap, legal consequences and/or fines for owners/operators. It is best advised that the recommended repairs, corrective actions and procedures be fully and accurately complied with in order to meet the required and applicable federal, state and local regulations, and to have the necessary repairs and up-grades performed prior to making any change in service, product and/or current conditions. Some recommendations and requirements are necessary to bring the component(s) into compliance with federal, state, and local regulations. InterSpec, LLC recommends re-inspection after any corrective action, repair or change in usage when the change is to a more severe service. Any change in facility conditions that are applicable to this inspection report, such as, but not limited to, a change in service or usage could result in outdating this report. The predictability of any component in this report is a result of following the procedures in the applicable industry standard. InterSpec, LLC accepts absolutely no responsibility or liability for any mishap or failure, including any subsequent clean-up costs or legal ramifications, resulting from owners’/operators’ failure to perform the required repairs, inspections and re-inspections, as they apply.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 3

Executive Summary

An API Standard 653 Out-of-Service inspection of Tank # 3473 was completed on October 03, 2017 to evaluate the tank’s integrity, collect data, and establish a database for future inspections and evaluations.

A service life evaluation performed on the tank shows it as having greater than 30 years of remaining shell life under current conditions. Inspection Results are listed in section 4.1. Maintenance Recommendations are listed in section 4.2. Compliance Requirements are listed in section 4.3. All engineering calculations are provided in Appendix A.

The tank does not meet the compliance requirements mandated by federal, state, and/or local regulatory bodies and requires that corrective action(s) be taken; however, the tank does meet requirements for structural integrity in accordance with the API-653 standard. The owner/operator may follow the schedule(s) in section 4.4. Refer to Compliance Requirements section 4.3 for details.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 4

Table of Contents

1.0 Introduction

1.1 Purpose

2.0 References

2.1 Code of Federal Regulations (CFR)

2.2 American Petroleum Institute (API)

2.3 American Society of Mechanical Engineers Codes (ASME)

2.4 National Fire Protection Association (NFPA)

2.5 American Society of Nondestructive Testing (ASNT)

3.0 Description

3.1 Job Description

3.2 Tank Description

3.3 Service Description

3.4 Part Description

3.5 Joint Type Description

3.6 Inspection Description

3.7 Equipment Description

4.0 Inspection

4.1 Results

4.2 Maintenance Recommendations

4.3 Compliance Requirements

4.4 Serviceability

Appendices

A Engineering Calculations B Engineering Data C Engineering Drawings D API Checklists E Photographs F Verticality Study

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 5

1.0 Introduction

1.1 Purpose:

1.1.1 This report presents an analysis of data collected during an inspection conducted on October 03, 2017 for Tank # 3473, servicing Jet A , located at the US Air Force - Andrews AFB facility in Andrews AFB, MD. The inspection was performed by a certified API-653 inspector. This report summarizes the results of the inspection meeting the requirements of API Standard 653 and API-650. The primary and secondary containments including the supports, foundation, vents, gauges, and appurtenances were evaluated. The inspection was conducted by InterSpec, LLC.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 6

2.0 References

2.1 Code of Federal Regulations (CFR):

United States Department of Labor, Occupational Safety & Heath Administration

2.1.1 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part 1910, Subpart H, Section 119, Process safety management of highly hazardous chemicals

2.1.2 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part 1910, Subpart J, Section 147, The control of hazardous energy (lockout/tagout)

2.1.3 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part…