Attachment J.4 Fac 5025 - 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 5025

Tank 25

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

USACE POL-MCX

16 January 2018

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. Leak Detection

4. Tank Bottom

5. Cathodic Protection System

6. Tank Shell

7. Tank Appurtenances

8. Tank Coating

9. Tank Piping System

10. Fire Protection System

11. 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

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

APPENDIX C: DESIGN DRAWINGS

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 AST Inspections at various facilities throughout the CONUS. For Facility 5025, (locally known as Tank 25) at Andrews Airforce Base in Morningside, Maryland, an API 653 Out-of-service (internal and external) inspection was performed. This inspection was completed on October 25, 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 5025, locally known as Tank 25, is a 43-foot and 6-inch diameter by 42-foot and 3-inch tall, single wall, vertical, field erected tank used to store jet fuel (F-24). The tank erector’s nameplate indicates the tank was built to API 650 9th Edition in 1998 and has a nominal storage capacity of 11,183 barrels. However, the nominal capacity listed on the nameplate calculates to be to the top of the shell (42 feet and 3 inches counting the rim angle). The capacity to the over flow is only 10,200 barrels. The tank’s aluminum internal floating pan was manufactured by Petrex. Tank bottom secondary containment and leak detection is provided by a liner under the tank bottom, which is connected by underground piping to four 16-inch monitoring wells in the dike basin. Dike area secondary containment is provided by concrete covered earthen berms. The design drawings indicate a liner under the concrete covering the dikes and dike basin. A concrete dike wall separates the dike area from that of the adjacent tank. Details of tank construction and appurtenances are also included in the Tank Information Table in

Section ‘B’. Our sub-consultant’s report is included in Appendix ‘A’. Additional photographs are included in

Appendix ‘B’. Design drawings, are included in Appendix C.

The tank was not returned to service following the inspection for the following reasons: Magnetic Flux Leakage

(MFL) examination of the tank bottom located a band of severe underside corrosion in a ring pattern located approximately 3 feet in from the shell, resulting in several areas with remaining thickness less than allowed by API

653. While the cathodic protection system appears to be producing somewhat less electrical current than indicated in the June 2017 inspection report, it is unlikely the corrosion occurred in the few months since then; and the pattern of corrosion suggests it is above the level of the water (at the air-water interface) where the cathodic protection system would have little effect. Also considered Mandatory to be addressed prior to returning the tank to service, is the condition of the internal floating pan perimeter foam log seal, which was found to have failed and was dripping fuel all around the perimeter. A ten-foot long section of the foam log perimeter seal was found to be collapsed and starting to fall apart. The tank was found to be otherwise in good condition, but with some minor deterioration, and some appurtenances design deficiencies.

Recommendations for addressing the deficiencies are included in Section C of this report. The repairs should be performed in accordance with API 653 and military criteria. The repair plan and the completion of the repairs should be reviewed and inspected by an API 653 Inspector. The schedule for the next API 653 Out-of-service

(internal and external) Inspection should be determined by the API 653 Inspector who assesses the repairs.

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.

API 653 0ut-of-Service Inspection Report Andrews Air Force Base - Morningside, Maryland

THIS INSPECTION

API Out-of-Service (internal and external) Inspection Date:

Equipment Used:

25 0ctober 2017

(See sub-consultant report.)

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Jnspection Date:

API In-Service (External) Inspection Date:

Dec 2007

Jrine 2015

ST ATE REGULATIONS

State Regulation for API In-Service Tank Inspections

State Regulation for API Out-of-Service Tank Inspections

RECOMMENDED FUTURE INSPECTION DATES

API Out-of-service (Internal) Inspection Date:

API Ultrasonic Thickness Inspection of Shell Date:

APIIn-Service (External) Inspection Date:

Pending review of completed Mandatory repairs.

October 2032

October 2022

Mike O'Connor

Mechanical Designer

API 653 Inspector No. 6230

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S. Air Force

Location Joint Base Andrews

Facility Number 5025

Tank Number Tank 25

State / Country Maryland / U.S.A.

City Morningside

Inspection Date October 25, 2017

Tank Manufacturer Matrix Service

Design Standard API 650, 9th Edition

Date of Construction 1998 (per nameplate)

Tank Contents Jet fuel (F-24)

Tank Serial Number EC-811

Tank Diameter 43’-6”

Shell Height 42’-3”

Product Height 38’-8 1/2” (limited by overflow)

Tank Capacity 10,200 bbl nominal (bottom to overflow). 8,400 useable (LLA to HLA)

Foundation 6” high concrete ring wall.

Construction/Material

Bottom 1/4-inch lap welded plate cone-down carbon steel of unknown grade.

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

Floating Roof Petrex aluminum honeycomb pan.

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

Cathodic Protection Impressed current.

Interior Coating System Interior 100% coated, likely epoxy.

Exterior Coating System Epoxy/polyurethane assumed.

Level Gauging Enraf ATG, Shand and Jurs Autogauge, 2” Vito water bottom probe well, 8-inch manual gauge well, 8-inch manual gauge ladder well.

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

Piping Receipt 8” Welded stainless steel

Issue 12” Welded stainless steel Water Draw-off 3/4” Stainless steel

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

Cleaning, Inspection, Repair In-service inspection 2015. Cleaned and out-of-service inspected in 2007.

RPB/Leak Detection Under bottom liner, 4 leak detection wells.

Stairs/Ladders Circumferential stairway with upper landing. Internal ladder

Manholes Two 36-inch lower shell manholes. 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 covered liner over earthen berms and dike basin.

Fire Protection System (2) fire hydrants within 300 feet.

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

This project will perform SPCC Mandated AST Inspections at various 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 5025 (Tank 25), an API Standard 653 Out-of‐service (internal and external) Inspection was performed.

2. Site Information

On October 24 and 25, 2017 Brockenbrough and our subconsultant InterSpec performed API 653 Out-of‐service (internal and external) Inspection of Facility 5025 (Tank 25) located at Andrews Air Force

Base, which is located in Morningside, Prince George's County, Maryland.

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 Air Force

Base.

3. Previous Repairs

Base personnel indicated no repairs have been performed on the tank since its construction. However, the coating repairs evidenced by the variations in the color/shade of the internal coating, suggest the autogauge (tape gauge), Enraf ATG stilling well, and Vito water probe were retrofitted.

4. Future Projects

Base personnel indicated the only known future project affecting the tank is repair of the tank bottom to foundation seal scheduled to be performed on 2 November 2017.

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/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

Tank Facility 5025 is a 43‐foot and 6-inch diameter by 42-foot and 3-inch tall, Jet Fuel (F‐24) aboveground vertical storage tank. The tank erector’s nameplate indicates the tank was constructed in

1998 and its nominal capacity is 11,183 bbl. However, the capacity to the overflow is only 10,200 bbl, while the capacity between the sub low and high level alarms (useable capacity) is only approximately

8,400 bbl. The capacity listed on the nameplate includes the air above the overflow to the top of the shell. The tank has a cone down bottom, with a center sump, a Petrex aluminum honeycomb internal floating pan, and a cone roof.

2. Tank Foundation

The tank rests on a 6-inch high ringwall foundation. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. There are approximately 25 unsealed radial cracks in the top of the ringwall foundation. A shell settlement survey was performed during the inspection in accordance with Appendix B of API Standard 653. The shell settlement evaluation indicates the settlement of the bottom of the shell and perimeter of the tank bottom is within the applicable limits for the method of evaluation described in API, and is within tolerance for new construction. 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. Leak Detection

The design drawings included in Appendix D indicate each of the four 2-inch tank bottom leak detection tell-tale pipes extend inward under the tank bottom and terminate on that end halfway to the sump and terminate on the other end with a valve located in one of the four 16-inch monitoring wells located in the dike basin. The monitoring wells are sealed with 16-inch threaded plugs and are difficult to access.

Opening one of the wells and leak detection valves in the well allowed a significant amount of water to drain out from under the tank bottom.

4. Tank Bottom

The lap welded cone down bottom slopes down to a center sump. The tank bottom was examined by magnetic flux leakage technology. Magnetic Flux Leakage (MFL) examination of the tank bottom located a band of severe underside corrosion in a ring pattern located approximately 3 feet in from the shell. The ultrasonic thickness measurements of the tank bottom at the locations of the underside corrosion indicate the tank bottom is not suitable for return to service without significant repair or replacement. The internal coating appeared to be in good condition. However, the floating roof striker plates are glued to the tank bottom rather than welded as required by API 650. In addition, the striker plates are stainless steel, which could cause galvanic corrosion of the interior of the tank bottom in the presence of water.

5. Cathodic Protection System

An impressed current cathodic protection system is installed on the underside of the tank bottom.

While the cathodic protection system appears to be putting out somewhat less electrical current than indicated in the June 2017 inspection report, it is unlikely the corrosion occurred in the few months since then; and the pattern of corrosion suggests it is above the level of the water (at the air-water interface) where the cathodic protection system would have less effect. The output readings in the control box read 4 volts and 0.2 amps.

6. 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. Although some minor peaking of the vertical shell seams was noted, the shape of the shell appears to be within the allowable tolerances of API Standard 653. The shell coating was evaluated for deterioration and found to be in good condition. However, much of the lower part of the shell is covered with mold and algae.

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.

7. Tank Appurtenances

a. Tank Roof

The tank’s steel, lap welded cone roof shows sign of isolated minor water ponding in a few places.

There are 22 rafters. The rafters are spaced 74 1/2 inches apart at 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 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 generally cracked and saturated with fuel. A 10-foot section of the foam log primary seal, located on the south southwest, was noted to have collapsed and is falling apart. The floating pan perimeter is not suitable for continued use.

c. Venting

The tank has a 24-inch diameter roof center vent, 4 perimeter vent inspection hatches, and 4 shell overflow/vents. Two of the perimeter vent inspection hatches have broken latches. Two of the overflows are over the stairs. API 650 discourages placing overflows over stairways or nozzles.

d. Gauging

The tank’s Enraf ATG is installed in an 8-inch flanged aluminum stilling well mounted through a 10-inch roof nozzle. A Vito water probe is installed through the neck of the center vent and through a

2-inch stilling well. The water probe is too long, with the result that the bottom end of the water probe is lying against the sump piping and may not be effective. Manual gauging may be performed through the 8-inch ladder stilling well under the roof manhole cover, which is equipped with a gauge hatch. Manual gauging may also be performed through the 8-inch stilling well which is mounted through a 10-inch flanged roof nozzle, which is equipped with a floating plug retriever.

The Shand and Jurs autogauge (tape gauge) is connected to the floating pan, with the result that the interior mechanism of the gauge head is damaged. The autogauge is not functioning. The manual and ATG stilling wells are welded to the 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 and high-high level alarms. Guidance for new construction provided in UFC 3-460-01 and DoD Standard Design AW 78-24-27 include both high and high-high level alarms as well as low and low-low level alarms above the low leg level of the floating pan. Although the level alarm panel indicates a low level alarm, there is no low level alarm above the low leg level of the floating pan. There is however a sub-low level alarm set at approximately one foot below the low leg level of the floating pan. The high level alarms are accessible from the circumferential stairway but are not testable due to interference with the stairway.

f. Stairs, Landings and Ladders

The tank’s steel cone roof is accessible by a circumferential stairway mounted on the shell of the tank. While the normal rise of the stairway steps is approximately 9 1/2 inches the bottom step is approximately 15 1/2 inches above the dike basin. There is no upper shell manhole or lower landing in the circumferential stairway for accessing the floating pan at the high leg position. The circumferential stairway also does not include an intermediate landing for accessing the high level alarms and controls. There is only 12 inches of clearance between the high level alarm and the stairway handrail and only approximately 4 feet of vertical clearance. OSHA requires stair steps to have a minimum width of 22 inches and 7 feet of overhead clearance. API requires 28 inch wide tread.

g. Grounding and Bonding

There are four grounding cables bolted to lugs, which are welded to the shell. The cables penetrate the dike basin through the dike basin to ring wall seal. The cables to grounding rod connections are accessible in cavities in the concrete dike basin. The ground rods and cables penetrate the dike concrete basin through unsealed cavities in the concrete; however, the design drawings indicate a liner under the concrete.

h. Shell Manholes

The tank has two 36-inch shell manholes. The shell manhole covers are hinged.

8. Tank Coating

The interior and exterior of the shell are coated. The exterior shell coating appears to be in good condition, but with some mold and algae covering the lower areas. There is isolated but scattered coating failure on the exterior of the roof. There is also is coating failure and corrosion on the roof appurtenances, bolting, roof guardrail, shell nozzle isolation valves, and level alarm chambers. The high and high-high level alarm conduit clips are also corroded. The interior coating appears to be in good condition.

9. Tank Piping System

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

10. Fire Protection System

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

11. Secondary Containment

Secondary containment is provided by concrete covered earthen berms. The design drawings indicate a liner under the concrete covering the dikes and dike basin. A dike wall separates the dike area from that of the adjacent tank. The dike drainage swale is approximately 10 feet from the tank. A large pool of rain water was observed on the side of the dike basin opposite the dike drain and appears undrainable. The issue piping is routed 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. Draining the rainwater that had collected in the dike area overnight down to the top of the secondary containment drainage sump 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 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 20 inches of free board. Guidance for the design of new tanks included in UFC 3-460-01 includes only 12 inches of freeboard.

C. FINDINGS AND RECOMMENDATIONS

With the exception of a few Mandatory repairs, Tank Facility 5025 was found to be in generally good condition. However, the tank is not serviceable in its current condition due to the Mandatory Repairs that are required to be performed before the tank can be returned to service. In addition, 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 should remain out-of-service until completion of these repairs.

a. Replace the Tank Bottom

OBSERVATION: MFL examination of the tank bottom identified a band of corrosion approximately 3 feet in from the shell and extending all around the tank bottom with thinning to less than 0.050 inches of remaining thickness, and many areas within the band with remaining thickness less than

0.100 inches. It should be noted that the technology is not capable of scanning areas within 2 inches of the lap welds or obstructions. There are four 16-inch monitoring wells located in the dike basin. The monitoring wells are sealed with 16-inch threaded PVC plugs and are difficult to access.

Vacuuming the water out of one of the wells and opening the 2-inch leak detection valve in that well allowed a significant amount of water to drain out from under the tank bottom. While the cathodic protection system appears to be putting out somewhat less electrical current than indicated in the

June 2017 inspection report, it is unlikely the corrosion occurred in the few months since then. The pattern of corrosion suggests it is above the level of the water (at the air-water interface) and above the settled sand pad, and therefore above the area where the cathodic protection system could have been effective.

REFERENCE: API 653 paragraph 4.4.5.3 and Table 4.4 require the tank bottom to be repaired or replaced when the remaining thickness of a tank bottom with leak detection and secondary containment is less than 0.050 inches.

RECOMMENDATION: Replace the tank bottom by the shell slotting method, and under the new tank bottom, provide a liner, sand pad, cathodic protection, and leak detection. Arrange to have an API

653 Inspector review the repairs and make recommendations for scheduling the next internal inspection.

Outline of

Band of underside corrosion

b. Replace the Floating Pan Perimeter and Penetration Seals

OBSERVATION: The internal floating pan perimeter foam log seal was found to have failed and was dripping fuel all around the perimeter. A ten-foot long section of the foam log perimeter seal is collapsed and is starting to fall apart. The penetration seals are also deteriorated.

REFERENCE: Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes flexible wiper squeegee primary and secondary periphery seals made of closed cell cast urethane.

RECOMMENDATION: Replace the internal floating pan periphery foam log seals with closed cell cast urethane flexible wiper squeegee primary and secondary seals. Replace the floating pan penetration seals with material similar to the periphery seals.

Foam log periphery seal

Fuel Drip

Top of pan Foam log periphery seal

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. Replace Level Control Valve

OBSERVATION: The level control valve is made of aluminum.

REFERENCE: NFPA 30 paragraph 27.4.3 and UFC 3-460-01 paragraph 3-6.7.1 prohibit valves made of aluminum and other low melting point materials.

RECOMMENDATION: Replace the aluminum level control valve with a steel valve.

b. Replace the Cathodic Protection System

OBSERVATION: The tank was built in 1998 with the impressed current cathodic protection system under the tank bottom. The cathodic protection (CP) system rectifier multiuse meters indicate 4 volts, and only 0.2 amps. Review of cathodic protection inspection reports indicate the readings for this tank and the sister tank have been historically much higher. The system may be near the end of its useful life.

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

24-27 and UFC 3-460-01 include cathodic protection under tank bottoms.

RECOMMENDATION: When the tank bottom is replaced, replace the cathodic protection system.

c. Provide Leak Detection

OBSERVATION: The design drawings included in Appendix D indicate that each of the four 2-inch tank bottom leak detection tell-tale pipes extend under the tank bottom only halfway to the bottom sump and terminate on the outside with a valve located in one of the four 16-inch monitoring wells located in the dike basin. The drawings do not indicate means to drain the center portion of the underside of the tank bottom. The monitoring wells are sealed with 16-inch threaded plugs, which are difficult to open. The wells are non-standard design and were not recognized as monitoring wells by POL personnel prior to the inspection. However, one of the leak detection wells was opened using a 6-foot long piece of 1 1/2-inch unistrut to apply torque. Some of the wells are located where there are obstructions that would complicate opening. The non-standard leak detection pipes and wells resulted in the buildup of water under the tank bottom, which may have contributed to the underside corrosion and necessity of replacing the tank bottom.

REFERENCE: Guidance for replacing tank bottoms provided in API 653 paragraph 9-10.2.6 and UFC

3-460-01 paragraph 12-3.3 includes providing a new bottom above the existing bottom, and providing leak detection piping that penetrates the shell below the new bottom for easy access.

Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes leak detection/drain piping extending to under the tank bottom sump.

RECOMMENDATION: When the tank bottom is replaced by the shell slotting method, provide leak detection piping per the latest military criteria.

Leak Detection Well

Inaccessible Leak Detection Well

Water in Leak Detection Well

Unistrut Used to Remove

16-inch Threaded Well Plug

d. Modify Stilling Well Guides

OBSERVATION: The ATG well, manual gauging well and internal ladder are attached to the tank roof as well as bolted to their bottom end guides, which are welded to the tank bottom. The bolts attaching the ATG well to the bottom end guides protrude through to the inside of the well and could cause the ATG to hang up.

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: When the tank bottom is replaced provide new well guides in accordance with current military criteria. Ensure the U-bolts at the top of the ladder side rails are double nutted to the ladder access opening and do not restrict the vertical movement of the ladder.

e. 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 tank bottom, or the pan support legs make contact with the stainless steel striker plates.

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 the tank bottom is replaced, provide PTFE feet on the bottoms of the IFR support legs. Ensure that stainless steel IFR support leg striker plates are not installed.

f. Modify the Diffuser

OBSERVATION: The receipt diffuser discharges horizontally approximately one foot above the tank bottom.

REFERENCE: Guidance for new construction provided in UFC 3-460-01 paragraph 2-19.01 and DoD

Standard Design includes a diffuser design that limits free falling of the fuel and creation of static by angling the diffuser down to within 4 inches of the tank bottom.

RECOMMENDATION: Modify the diffuser to limit free falling of the fuel and creation of static by angling the diffuser down to within 4 inches of the tank bottom.

g. Provide Valve on Water Draw-off Nozzle

OBSERVATION: There is no isolation valve or electrical isolation flange kit on the water draw-off nozzle. The product saver tank piping is stainless steel. The product saver tank is not grounded.

REFERENCE: NFPA 30 – 22.13.1 requires isolation valves to be located as close to the shell as practical. Guidance provided in DoD Standard Design AW 78-24-27 includes isolation valves on tank nozzles. Guidance for new construction 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: Provide an electrical isolation flange kit and an isolation valve on the water draw-off nozzle. Provide a grounding system for the product saver tank. Do not bond the product saver tank to the grounding of the tank in order to maintain some degree of electrical isolation.

h. Provide OSHA Compliant Internal Ladder Access Hatch

OBSERVATION: The 36-inch internal ladder access manhole provides approximately only 28 inches of clearance on the climbing side of the ladder. The cover is not bolted and does not have a rain lip.

REFERENCE: OSHA regulation 29 CFR 1910.27 (c) requires 30 inches of clearance (24 inches with a deflector plate) on the climbing side of a ladder including at access hatches. Guidance for new construction provided in DoD design Standard AW 78-24-27 includes an OSHA compliant internal ladder access hatch with a rain lip.

RECOMMENDATION: Provide an OSHA compliant internal ladder access hatch with a rain lip.

i. Modify Stairway

OBSERVATION: Clearance between the stairway handrail and the high level alarm piping is only 12 inches. The high-high level alarm is untestable due to interference with the stairway. The rise of the stairway steps is generally 9 1/2 inches; however, the bottom step is approximately 15 1/2 inches above the dike basin. There is no upper shell manhole or intermediate landing for accessing an upper shell manhole.

REFERENCE: OSHA regulation 29 CFR 1610.25 (c) (4) (December 2017) requires clearance at a stairway of at least 22 inches. The minimum width of stairs required in API 650 Table 5.18 has increased over the years, from 24 inches in 1993 to 28 inches in the latest edition. Guidance for new construction provided in DoD Standard Design AW 78-24-27 includes upper shell manholes for accessing the internal floating pan at high leg position, landings on circumferential stairways to access high level alarms, controls, and the upper shell manhole. OSHA regulation 29 CFR 1910.25

(b) (3) (December 2017) requires the step rise to be uniform throughout any flight of stairs.

RECOMMENDATION: Provide an upper shell manhole. Modify the circumferential stairway to provide lower and intermediate landings to access level alarms, controls, and the new upper shell manhole while proving 28 inches of horizontal clearance and a continuous rise from ground level or a bottom landing.

j. Provide Level Alarm Test Tubing

OBSERVATION: There is no alarm test tubing for testing the high level alarms and controls using the product saver tank return pump. Manual testing requires personnel raise a bucket of fuel high above the stairway and pour fuel into a funnel on top of the alarm piping, which often results in spilled fuel covering the tank, the dike basin, and personnel.

REFERENCE: Guidance for new construction included in AW-78-24-27 includes tubing from the product saver tank return pump for testing the high level alarms and controls.

RECOMMENDATION: Provide alarm and control test tubing from the product saver tank return pump for testing the high level alarms and controls.

k. Replace Nuts and Bolts

OBSERVATION: The bolting on the Enraf chamber flanges, pan installation hatch, and roof center vent as well as the clamps on the high level alarm conduit 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: Provide new with corrosion resistant bolting on the Enraf chamber flanges, pan installation hatch, and roof center vent. Replace the high level alarm conduit clamps.

l. Repair Coatings

OBSERVATION: There is scattered coating failure on the exterior of the roof, and coating failure and corrosion on the floating plug retriever nozzle flange, pan installation hatch cover, roof guardrail, autogauge guide pipe, interior of the roof manhole cover and flange, and the interior of the roof perimeter vent/inspection hatch hoods. There is also coating failure and corrosion on the receipt and issue DBB valves, and on the level alarm sensor chambers.

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

RECOMMENDATION: Replace the coatings on the exterior of the roof including on the floating plug retriever nozzle flange, pan installation hatch cover, the roof guardrail, autogauge guide pipe, interior of the roof manhole cover and flange, and interior of the roof perimeter vent/inspection hatch hoods. Replace the coatings on the receipt and issue DBB valves, and on the level alarm sensor chambers.

m. Rehabilitate the Foundation

OBSERVATION: The tank bottom to foundation seal has generally failed. There are approximately

25 radial cracks in the concrete ringwall foundation. The ringwall foundation is sloped toward the tank bottom which forces rain water under the tank bottom.

REFERENCE: NFPA 30 paragraph 22.11.2.4 and CFR 112.7(c)(1) require secondary containment to be liquid tight. Guidance for new construction provided in DoD Standard Design AW 78-24-27 and

UFGS Specification 33 56.13.13 include installation of the tank bottom to foundation seal to be performed by a coating contractor and sloping the exposed foundation away from the tank bottom.

API 650 Figures B.1 and B.2 require the top of the ring wall to be level or sloped away from the tank bottom. Guidance for new construction provided in DoD Design Standard AW 78-24-27 also includes sloping the top of the ring wall away from the tank bottom. The example inspection checklist included in API 653 Appendix C includes item – C.1.1.1.d), which cites examining the ringwall foundation to note if runoff rainwater from the shell drains away from the tank.

RECOMMENDATION: Slope the exposed top of the concrete ringwall foundation away from the tank bottom. Seal the cracks in the concrete foundation. Coat the underside perimeter of the tank bottom and replace the tank bottom to foundation perimeter seal. Seal coat the foundation.

Crack in Ringwall

n. Provide Latches

OBSERVATION: The four (4) roof perimeter vent/inspection hatches have one latch each. Two of the hatches have broken latches.

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

RECOMMENDATION: Provide new latches on two of the roof perimeter vent Inspection hatches.

o. Reinstall Water Probe

OBSERVATION: The Vito water probe is installed through the neck of the center vent and through a

2-inch stilling well. The water probe is too long, with the result that the bottom end of the water probe is lying against the sump piping and may not be effective.

Reference: Guidance for new construction provided in UFC 3-460-01 Table 8-1 item p and DoD

Standard Design AW-24-27 include a water probe over and in the bottom sump. Manufacturer’s installations instructions for the Vito Water Probe include the following caution: “There should be at least 50 mm (2”) free space between the sensitive part of the water probe and the tank shell (or any other large metal part in the tank, i.e. stilling well).”

RECOMMENDATION: Reinstall the Vito Water Probe per the manufacturer’s instructions.

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. Continue to Remove Algae

OBSERVATION: Due to the undrainable area of the secondary containment, a considerable quantity of algae collects in the dike area.

Reference: Guidance for maintenance of fuel storage facilities provided in UFC 3-460-03 paragraph 8-10.3.1 includes inspection of dike areas for cleanliness and removal of debris and vegetation. NFPA 30 paragraph 22.11.2.8 prohibits storing combustible material in the dike area.

RECOMMENDATION: Continue to remove the algae from the dike area.

b. Pressure Wash the Roof and Lower Shell

OBSERVATION: Bird droppings were observed on the roof and guardrails. Scattered coating failure was also noted on the roof. There is isolated stain from water ponding on the perimeter of the roof.

The lower portion of the shell is coated with mold and algae.

REFERENCE: API 570 paragraph 4.3.2.3.h) reads, “bird turds can also cause accelerated corrosion and unsightly stains.”

RECOMMENDATION: In the periodic maintenance checklist, include pressure washing of the lower portion of the shell and the tank roof to remove bird droppings and loose debris.

c. Seal Concrete Dike Area Cracks

OBSERVATION: There are approximately 800 linear feet of cracks in the concrete covering the dike basin and 400 linear feet of cracks in the concrete covering the dike berms. The design drawings indicate a liner under the concrete ballast. Although the integrity of the line could not be visually verified, the liner seemed to be intact, based on the operators observations of retained rain water.

REFERENCE: Guidance for operation and maintenance of fuel facilities provided in UFC 3-460-03 paragraph 8-10.2 includes inspection of dike areas, removal of vegetation, and sealing of cracks.

RECOMMENDATION: As there is a liner under the concrete, sealing the cracks is not required.

However, to inhibit growth of vegetation and further deterioration, and to simplify evaluation of the dike for environmental regulators, seal all of the cracks in the concrete covering the dike liner.

Some of the cracks that should be repaired are shown in a sketch in our subconsultants report.

d. Tighten Enraf Access Door Latches

OBSERVATION: The Enraf access door latches are loose and may allow rain water to enter through the edges of the door cover.

REFERENCE: NA.

RECOMMENDATION: Tighten the Enraf Access Door Latches.

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. Eliminate Unnecessary Overflows

OBSERVATION: The tank has four shell overflows each with approximately one square foot of net open area. One is located over the top of the stairs. One is located over the bottom of the stairs.

Fuel is received into the tank through 8-inch piping capable of a flow of 1800 gpm at 12 feet per second.

REFERENCE: API 650 paragraph H.5.3.3 does not recommend locating overflows over stairways or tank nozzle isolation valves. Guidance for new construction included in DoD Standard Design shows only one overflow with 2 square feet of net open area on both 10,000 and 20,000 bbl tanks with 8-inch receipt nozzles. The overflow shown in the Standard Design is on the side of the tank opposite the product nozzles and not over the stairway.

RECOMMENDATION: Eliminate the two shell overflows located over the circumferential stairway, and repair the shell at those locations. Verify the capacity of the remaining overflows are adequate and if necessary provide overflows to meet the latest military criteria and capacity.

Overflow

Receipt

Issue

Issue

b. Provide Scaffold Cable Supports

OBSERVATION: There are no scaffold cable supports on the fixed roof.

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

RECOMMENDATION: The next time interior tank coating work is performed, provide two scaffold cable supports on the fixed roof.

c. Provide API Compliant Internal Pipe Support Mounting Plates

OBSERVATION: Three internal pipe support weld-on base plates are closer than 2 inches to a tank bottom weld seam. In addition, the anti-rotation cable base plate is closer than 2 inches to a tank bottom weld seam.

REFERENCE: In later editions of API 653, paragraph 9.10.3.1 and Figure 9.13 require welds attaching plates to the tank bottom to be at least 2 inches from bottom lap welds. API 653 paragraph 9.10.3.1 allows existing noncompliant weld spacing to be accepted at the time of modification, if the welds are MT or PT examined. The above requirements were incorporated into API 653 some years after the plates were installed, and API 653 does not require MT or PT of existing welds on tank bottoms that do not meet weld spacing requirements but have been in service.

RECOMMENDATION: When the tank bottom is replaced ensure the pipe support mounting plates and the anti-rotation cable anchor mounting plate meet API 653 for size and weld spacing.

d. 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. As a result, approximately one thousand gallons of jet fuel that would normally be transferred from the tank into the adjacent tank is wasted every time the tank is cleaned. Considering the value of the fuel and the cost of disposal of the fuel, water, and sludge mixture, the potential loss to the government in 32 years is approximately $20,000.

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 78-24-26 include hard piping the low suction to the main suction.

RECOMMENDATION: Provide piping and valves to connect the low suction piping to the issue piping.

e. Provide Removable Mid-rail Chain

OBSERVATION: There is no mid-rail or removable mid-rail chain above the roof perimeter vent/inspection hatches.

REFERENCE: 29 CFR Part 1910.23 (c) requires every open-sided floor or platform 4 feet or more above adjacent floor or ground level to be guarded by a standard railing. Guidance for design of the new tanks provided in DoD Standard Design AW 78-24-27, includes a guardrail around the top of vertical ASTs, Detail 1/D.09 indicates a removeable intermediate guardrail chain above the perimeter vent/inspection hatches.

RECOMMENDATION: Provide steel angle top rails with removable mid-rail chains above the perimeter vent/inspection hatches.

Low Suction

Main Suction

f. Replace Autogauge

OBSERVATION: The Shand and Jurs autogauge tape is connected directly to the floating pan. As a result, the gauge is inoperable. The operator and some branches of the military do not consider an autogauge necessary equipment.

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

RECOMMENDATION: Consider providing a new autogauge with the tape attached to a weight resting on top of the floating pan, or also providing a well and float in the pan and attaching the autogauge tape to the float.

g. Provide Exothermic Grounding Connections

OBSERVATION: The tank’s grounding cables are bolted to shell mounted lugs.

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: Consider providing exothermically welded grounding connections.

Autogauge

Tape/wire

Autogauge Head

h. Modify Thermal Relief Piping

OBSERVATION: The issue and receipt piping thermal relief valve data plates indicate set pressures of

265 psig, and an applicable range of 226 to 400 psi. If the pumps are not oversized, the actual pump deadhead would normally be expected to be in the 60 to 150 psi range. Excessively high TRV settings reduce the life of gaskets, cause expansion strains in piping, and may lead to other problems such as underground leaks. Conventional Pressure Testing and Qualified Leak Testing requirements as described in the last IMP are based on pressure not less than the greater of pump deadhead pressure or 110% of the thermal relief valve settings. It should be noted that the 2013

IMP reported the west hydrant system pumps appear to provide a higher pressure than necessary, and that pressure surge of up to 290 psi was observed. The IMP also noted a history of leaks in the west hydrant system and recommended a full thermal relief study. The receipt and issue thermal relief piping includes sight flow indicators but does not include testing tees. 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-

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