Attachment J.4 Kwajalein-Fac 951 (Tank 8)-FINAL-2017.pdf

US Army Corps of Engineers Omaha District

API 653 Out-of-Service Inspection Report

U.S. Army Garrison Kwajalein Atoll Facility Number 951

Tank Number 8

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

(USACE POL-MCX)

September 29, 2017

API 653 Out-of-Service Inspection Report USAG Kwajalein-Atoll

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION DATE

STATE REGULATIONS

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

GENERAL TANK INFORMATION

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Tank Foundation

3. Tank Bottom

4. Tank Shell

5. Tank Appurtenances

6. Tank Coating

7. Tank Piping System

8. Fire Protection System

9. Secondary Containment

10. Cathodic Protection

C. FINDINGS AND RECOMMENDATIONS

1. MANDATORY REPAIRS per API 653, UFC 3-460-01, or AW 78-24-27 Standards

2. REQUIRED REPAIRS to Fully Comply with API 653 or Federal, State, and Local Codes…………………………………..14

3. RECOMMENDED REPAIRS as Part of Regular Maintenance………………………………………………………………………….26

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 BOTTOM SERVICE LIFE EVALUATION

A.2 SHELL SERVICE LIFE EVALUATION

A.3 SHELL SETTLEMENT EVALUATION

A.4 ULTRASONIC UT DATA

A.5 CONTAINMENT LAYOUT DRAWING

A.6 BOTTOM LAYOUT DRAWING

A.7 SHELL LAYOUT DRAWING

A.9 OSHA ACCESS STRUCTURE REPORT

APPENDIX B: 3-D DOCUMENTATION AND ANALYSIS

APPENDIX D: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX E: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

ARD Anti-rotation device

ATG Automatic Tank Gauge

BBL Barrel

CFR Code of Federal Regulations

CP Cathodic Protection

DFT Dry Film Thickness

HLA High Level Alarm

HLCS High Level Control Shutoff

HHLA High-High Level Alarm

LLA Low Level Alarm

LLLA Low-Low Level Alarm

MFL Magnetic Flux Leakage

MT Magnetic Particle Testing

NACE National Association of Corrosion Engineers

NDT Non-Destructive Testing

NFPA National Fire Protection Association

PSI Pounds per Square Inch

PT Penetrant Testing

P/V Pressure/Vacuum

RP Recommended Practice

PST Product Saver Tank

RT Radiography Testing

TML Thickness Measurement Location

TRV Thermal Relief Valve

UFC Unified Facilities Criteria

UFGS Unified Facilities Guide Specifications

ULS Ultra Low Sulfur

UT Ultrasonic Testing

VT Visual Testing

VPI Valve Position Indicator

GENERAL SUMMARY

Summary of Inspection

An API Standard 653 Out-of-Service inspection Tank 8 (Facility 951) at USAG Kwajalein-Atoll, Republic of the Marshall Islands was completed on September 29, 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. The bottom life evaluation performed on the tank shows it as having greater than 30 years of remaining life under current conditions. Inspection Results are listed in section C.

INSPECTION DATE

API Out-of-Service (Internal) Inspection Date: 29 September 2017

Equipment (s) Used:

Ultrasonic Thickness (A-scan/B-scan) Testing Manufacturer: General Electric Model: DMS Go+ Calibration Methods Used: Zeroing Procedure, Copper Coating Calibration Procedure, and Two Point

Calibration Procedure

Tank Bottom Scanner Manufacturer: MFE Enterprises Model: 2412 Mark II Calibration Methods Used: Sensitivity adjacent on manufacturer supplied test plate with simulated anomalies and notch

Tank Bottom Surveying Manufacturer: Northwest Instrument Model: NRL802K Rotating with NLD5G Laser Reciver Calibration Methods Used: Main and transverse horizontal axes checks at 100 ft. ≤ 1/16 inch

Tank Shell Surveying Manufacturer: Leica Geosystem Model: 3D Disto Calibration Methods Used: Tilt sensor calibration automatically performed with unit set at < 3° and crosshairs calibration using target at a distance > 25 m

Inspector(s): Benyam Berhane

STATE REGULATIONS

State Regulation for API In-Service Tank Inspections N/A State Regulation for API Out-of-Service Tank Inspections N/A

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

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: 21 March 2010 API In-Service (External) Inspection Date: 21 March 2010

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

API Out-of-Service (Internal) Inspection Date: 29 September 2037 (29 September 2027 IAW UFC) API In-Service (External) Inspection Date: 29 September 2022

Benyam Berhane Mechanical Engineer/Sr. Inspector InterSpec, LLC API 653 Certified Inspector No. 28492

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S Army

Location U.S. Army Garrison Kwajalein Atoll; RMI

Facility Number 951

Tank Number 8

State / Country Kwajalein Atoll / Republic of Marshall Islands

City -

Inspection Date 29 September 2017

Tank Manufacturer Unknown (Install Name plate to document upcoming repairs IAW API 653)

Design Standard Unknown (Assumed API STD 12C Eleventh Edition)

Date of Construction 1954

Tank Contents Mogas (F-46)

Tank Serial Number None

Tank Diameter 45 Feet

Shell Height 30 Feet

Product Height 26 Feet

Tank Capacity 7,500 BBL (315,000 Gallons)

Foundation Concrete Ringwall

Construction

Bottom Lap‐Welded (Slight center crown)

Shell Butt‐Welded (Cylindrical)

Floating Roof Flat Aluminum Honeycomb IFR

Fixed Roof Aluminum Geodesic Dome

Material

Bottom Carbon Steel (unknown specification)

Shell Carbon Steel (unknown specification)

Floating Roof Aluminum (unknown specification)

Fixed Roof Aluminum (unknown specification)

Cathodic Protection Impressed Current

Interior Coating System Thin Film Epoxy

Exterior Coating System Thin Film Epoxy/ Polyurethane

Level Gauging ENRAF Automatic Tank Gauge with Shand & Jurs 92021 Mechanical Tape

Overfill Protection Hydraulically Operated High Level Shut-off Valve with Dedicated Float (Set at

26.75 Feet)

Piping Receipt 6" Carbon Steel

Issue 6" Carbon Steel

Low Suction N/A None

Water Draw-Off 2" Carbon Steel

Level Alarms

Low‐Level Alarm: 4.49 Feet Low‐Low Level Alarm: 1.50 Feet High‐Level Alarm: 26.00 Feet High‐High Level Alarm: 28.45 Feet High‐Level Control Shutoff: 26.75 Feet

Type of Internal Floating Roof

Aluminum Honeycomb- with primary and secondary wiper perimeter seals

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

This project will perform API 653 inspections of various tanks at facilities throughout the United

States/OCONUS.

Additional consideration is given to federal, state, and local regulations, as well as applicable military criteria and general industry standards.

An API Standard 653 Out-of-Service (Internal/External) inspection was performed for Tank 8 (FAC

951).

2. Site Information

On September 29, 2017 Burns & McDonnell and our sub‐consultant (InterSpec) performed an API 653

Out- of‐Service (Internal and External) inspection of Tank 8 (Facility 951) located at U.S. Army Garrison

Kwajalein Atoll; RMI. USAG Kwajalein Atoll (USAG-KA) is home to the Ronald Reagan Ballistic Missile

Defense Test Site. The Reagan Test Site is Major Range and Test Facility Base under the DoD with primary mission of research, develop test and develop missile defense and space programs.

Tank 8 is used as an aboveground Mogas fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 8 (FAC 951) is a nominal 7,500 BBL, 45‐foot diameter by 30‐foot tall, F‐46 (Mogas), aboveground vertical storage tank. The tank was constructed in 1954 presumably to API STD 12C Eleventh Edition.

There are no Data or Name plates affixed on the tank. The tank has undergone several modifications, since the original construction. A flat aluminum honeycomb IFR, Aluminum Geodesic Dome roof, level alarms, high liquid level shut-off system, additional aluminum stilling wells, bottom patch plates repairs/removal and internal pipe support modification was noted as some of the alterations

2. Tank Foundation

The tank sits on a concrete ringwall foundation that is approximately 10" above the containment floor.

The foundation is not designed with a leak detection (tell-tale) system that extends to the center of the tank. The flexible membrane liner (FML) for the secondary containment is attached to the foundation with batten strips. Accessible sections of the foundation were visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. No spalling and vegetation were present. The foundation to chime interface is sealed. Minor sealant deterioration is present throughout, with an approximate total of 12 linear feet of deteriorated caulking identified. Shell settlement surveys were performed during the inspection in accordance with Annex B of API Standard

653. Settlement results are listed in Appendix A. There is no indication of significant settlement.

Overall, the foundation appears to be is in satisfactory condition (A small section of the foundation is accessible for inspection).

3. Tank Bottom

The bottom is constructed from carbon steel material with unknown specification. The bottom is a crown up design, lap-welded together, consisting of eighteen (18) plates fillet-welded to the shell. The bottom has a thin film interior liner. The interior coating was evaluated for disbonding, adhesion, deterioration, and discoloration and was found to be unsatisfactory. Isolated coating failure was noted throughout the tank bottom, shell-to-bottom area and sump. Active and inactive pitting was noted due to coating failure and coating holidays. Pit depth measured range from 0.040” to 080”. A close visual inspection of all the welded-on plates was performed for indications of cracked welds, cracked coating, and capillary effects of residues. No deficiency was noted with the welded-on plates. Dry film thickness

(DFT) readings typically ranged between 7 - 20 mils, with some areas near the shell-to-bottom and bottom lap-welds having a high coating thickness in the range of 21 to 30 mils.

Evaluated the bottom, bottom welds, and bottom‐to‐shell weld for corrosion, with no other discrepancies noted. Performed a magnetic flux leakage (MFL) evaluation of the tank bottom to determine the condition of the underside; ninety‐five plus percent was scanned. No areas indicating underside corrosion were located. An ultrasonic inspection of the bottom suggests a nominal thickness of 0.375".

Vacuum box testing was conducted on the tank bottom, shell to bottom welds, reinforcing plate and patch plates in accordance with API STD 650 section 8.6. Additional vacuum box was conducted on the accessible section of the sump-walls-to-sump-bottom weld as well as sump-to-tank-bottom welds

(corner welds were not tested due to configuration limitation). The vacuum box testing was conducted over the tank coating after tank bottom was pressure washed. Note: Vacuum box testing is typically applied after welding is completed but before coating is applied where all lag, splatter, dirt, oil, grease, coating or other contaminants are cleaned.

The bottom is equipped with a square sump measuring 35.75" x 35.625" x 12.375". A static test was conduct using water to test the condition of the sump welds. This was done by completely filling the sump with water and recording any variance in liquid level over a period of time. The sump static test was held for 24 hours and 40 minute with a measured level change of 0.125". This equated to a 0.69 gallon difference and loss of 0.0279 gallons per hour (GPH). This test did not account for any potential evaporation loss but assumes to be negligible because water was used as test liquid and the surface area is very small. Based on the calculated loss in the sump, the vacuum box testing, the MFL, UT and visual inspection performed did not indicate a loss in integrity of this AST. Therefore this inspection did not reveal any deficiencies in the “mandatory repair” category that preclude the tank's return to service.

However in light of the 2.01 GPH leak rate reported on the 2016 Annual Leak Detection Testing Report;

the following recommendations are presented:

a) Additional testing of the sump to confirm/deny potential leak. E.g.

i. Attain a custom corner vacuum box to isolate and test the corner welds in the sump

ii. Cold cut six-inch round holes inside the sump and in the bottom plates to do soil testing.

(Hot work and follow-up coating repair required).

b) Replace sump with improved standard cylindrical sump per AW 78‐24‐27 Drawing D.07 Detail

5. (See also API 650 Figure 5.21)

c) Remove (Sandblast) floor coating and retest with vacuum box. A related less comprehensive but more efficient approach would be to only strip the coating from all tank bottom seams and welds as it is not likely to see a breach in the seamless areas of its shell and bottom.

d) Conduct a helium mass spectrometer test, where helium is injected at 2 or 3 locations through

7/16” holes drilled in the bottom plates and sensitive helium leak detection equipment is used to detect for potential breach. (Hot work and follow up coating repair required).

e) Install a replacement bottom over the existing bottom by slotting method with a suitable noncorrosive material cushion such as sand and impervious liner with leak detection system.

f) Return Tank 8 to service and observe/test for leaks, by empirical observation followed by third party testing (See item j and k). This could be done in conjunction with, or preceding some of the above items.

If there is a decision to return the tank to service, some preliminary service repairs, coupled with a methodical procedure and combined oversight by the Base Fuels and Base Environmental Managers, are recommended along with the following:

g) Enraf ATG should be repaired, including all conduits (power and communication lines) back to the junction/relay boxes.

h) Repairing the thinning issue piping (located approximately mid-way between AST 9 and AST 8 skin valve). Recommend replacing the spool of piping before bringing the tank into continuous service.

i) Fill tank in stages to minimize impact and response time if a leak exists. First fill shall at least float the IFR. Monitor levels with Enraf and frequent manual tank level gauging.

j) Retest tank tightens after filling to operating level.

k) Retain Tank 9 as the primary In-Service MOGAS tank until a tightness test is conducted again on

Tank 8. The previous test was conducted while Tank 8 was the only MOGAS tank in operation.

l) Note Tank 9 was not tested for tightness during the 2016 Annual Leak Detection Testing Project

(it was OOS); recommend testing Tank 9 once Tank 8 is done.

4. Tank Shell

The tank shell is constructed from carbon steel material of an unknown specification. The shell is of cylindrical design, butt-welded together, and consisting of five (5) courses with one angle stiffening-ring approximately 14.5" from top of shell. Evaluated the shell for plumbness, roundness, peaking, and banding; all of which were found to be within the allowable tolerances of the API Standard 653. Visually inspected both the interior and exterior of the shell. Inspected the coating for disbonding, adhesion, deterioration, and discoloration. The tank shell is equipped with two 20"-manways (180° apart) and an additional 30" manway. The tank is equipped with shell mounted low level alarm, high-high level alarms, as well as a high-level shut-off. The shell was evaluated for remaining metal thickness utilizing ultrasonic technology. The ultrasonic thickness measurements and thickness measurement locations

(TML) are listed in the Shell Plate Thickness Measurements table in Appendix A. A service life evaluation performed shows the shell with greater than 30 years of remaining life under current conditions. The engineering calculations, as per API Standard 653, for the service life evaluation are shown in Appendix A under “Service Life Evaluation.” The tank shell is in satisfactory mechanical condition.

5. Tank Appurtenances

a. Internal Floating Roof

The tank is equipped with a full surface contact aluminum honeycomb internal floating roof

(IFR) manufactured by Petrex Inc. and is fitted with primary and secondary wiper perimeter seals. The IFR is resting approximately 74.50" (measured at the perimeter) above the tank bottom and is supported by eight (8) floating roof legs. Non-metallic (Teflon

Type) spacers are installed to isolate IFR legs from the carbon steel bottom. Evaluated the condition of the floating roof seals. The primary IFR perimeter seal and secondary perimeter seal are in good mechanical condition. Measured the annular space at several locations from the tank bottom, and the floating roof is determined to be properly centered inside the tank. Several corrosion areas on the top side of the IFR (likely from galvanic corrosion between AL and SS components including IFR grounding cable) were noted.

Several locations with 1 sq.-in to 2 sq. in corrosion spots with internal structure of the IFR visible were identified.

b. Geodesic Dome Roof

This tank is retrofitted with a clear span, aluminum dome cover manufactured by

Conservatek Industries. It is an aluminum geodesic dome roof that was retrofitted to this tank sometime within the past seven years. The dome is joined with stainless steel fasteners with an interlocking panel that has an enclosed gasket in compression for mechanical seal.

The batten bars and gusset cover are sealed with caulking (external joint seals) but is allowing some water onto the top of the IFR (small amount of standing water noted after heavy rain events on eight IFR panels primarily near the center and south east end of tank).

Additional investigation or testing may be required to determine the exact locations of water infiltration. There is minor caulking deterioration and signs of standing water on the fixed roof panels. Inspection of the dome roof is limited to what is accessible from the platform.

c. Gauging

The tank’s Enraf (Model # 854) ATG is installed through an 8-inch aluminum stilling well.

The stilling well is slotted. The Enraf system was not in working order at the time of the inspection. There is no manual gauging and sampling well but it appears this action is performed via the Enraf well by removing the access cover plug. A separate slotted 8-inch carbon steel well is used for the ATG water probe. The tank is equipped with a float and tape type mechanical tape gauge manufactured by Shand & Jurs (Model 92021). The mechanical tape gauge float is installed using guide wires and anchors mounted to a reinforcing plate on the tank bottom. The system is in good working condition and responded when the float was elevated above the tank bottom.

d. Level Alarms

The high level alarm, the HLV float chamber, and the high-high level alarm are mounted on the shell and are accessible via the circumferential stairway. The tank is equipped with a low-level alarm, but no independent low‐low level alarm system was installed, as required by military criteria.

e. Stairs and Platforms

The tank’s fixed roof is accessible by a circumferential stairway mounted on the shell of the tank with a top platform. The stair and platform were inspected for corrosion and structural soundness. The stairway handrail is constructed with 1½" angle iron handrails and coated steel plate threads with non-slip profile. The top platform and one of the top treads are galvanized grating type. The overall general condition of the stairs and platform are mostly satisfactory (with some exception – See Section C).

f. Grounding and Bonding

There is one grounding cable connected to lugs on the tank’s shell. The grounding rod penetrates through the secondary containment floor liner. The internal floating roof is bonded to the tank geodesic dome roof with two stainless steel cables. Tank is not equipped with copper grounding bar for personnel static electric discharge (typically required by military criteria).

6. Tank Coating

The tank shell, bottom, stairway, handrails, piping, and appurtenances are coated. The exterior coating appears to be an epoxy with polyurethane top. The exterior shell coating has minor chalking due to UV exposure with isolated coating failure on the upper section of the shell. Similar coating failure was noted on product piping and valves within the secondary containment.

7. Tank Piping System

The fuel is received through 6-inch carbon steel piping that is fitted with an inlet diffuser. The diffuser is rolled to a circular transition, with a final outlet diameter of NPS 12. The product is issued from the tank through a 6-inch carbon steel pipe that extends 90" into the tank. Other auxiliary piping for the water draw-off (NPS 2) terminates inside the tank bottom sump. Inspected and evaluated each tank nozzle in accordance with API Standards 650 and 653. Identified the type and use of each shell nozzle and measured the nozzle neck thickness on all accessible shell nozzles. Evaluated all nozzles and reinforcement plates for leaks and corrosion.

8. Fire Protection System

The storage tank is equipped with a surface application fixed foam fire suppression system that uses a mobile foam supply. Two NPS 2 foam outlets are mounted on the top edge of shell course five. All

Victaulic couplings for the fire suppression system piping have deteriorated fasteners. Serval locations have completely failed couplings. No fire hydrants were noted near the tank during the inspection.

9. Secondary Containment

The tank sits inside an earthen secondary containment basin with a geotextile liner and concrete dike walls. The overall dimension of the secondary containment is 131.25 feet x 149.75 feet, with a vertical height of 74.75". The secondary containment is equipped with a 6" drain inlet and a drain valve that tie to underground PVC piping system to the OWS. The secondary containment release valve is housed inside a vale pit adjacent to the drain inlet within the dike. The PVC piping system is manifolded together and cannot be individually isolated outside of the valve pit. The drain line and the drain inlet were hydrostatically tested to investigate if the drainage system was liquid tight. The drain pipe and release valve were tested with water by pressurizing to 10 psig using a pump connected to a pipe testing assembly. The test was conducted in accordance with the applicable requirements of AWWA

C600 for hydrostatic testing. The drain inlet was hydrostatically tested for integrity by filling the inlet with water to a level at least 1-2 inches above the top of the inlet structure. The drain inlet and release valve did not pass the hydrostatic test (leaking inside the valve pit between the PVC to valve flange).

The drain inlet passed with no measurable difference in water level. However, due to the breach in the inside of the valve pit (between the PVC to valve flange), the valve pit is not considered liquid tight.

Valve pit has rain covers but standing water was noted in valve pit.

The secondary containment was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation growth. Minor hairline cracks (temperature cracks) and some moderate cracks were noted in the secondary containment wall. An approximate total of 20 linear feet of cracks in the secondary containment wall were identified. Hairline cracks do not seriously affect the strength of the concrete structures; however, these cracks can be potential access points for moisture or water seepage that could corrode the reinforcing steel (rebar). There are several CP test port/anode access

PVC openings around the perimeter of the tank that penetrate the FML. Some of these PVC openings have deteriorated caulking. The secondary containment is mostly in satisfactory condition, with the exception of the discrepancies identified above. Field assessment indicates that the secondary containment is of sufficient size to contain a total tank loss. The secondary containment is sloped to allow for drainage away from the tank.

A formal secondary containment evaluation, in accordance with 40 CFR 112, may be required in order to satisfy federal, state, and local requirements.

10. Cathodic Protection

An impressed current Cathodic Protection (CP) system is installed on this tank that serves multiple

ASTs at the tank farm (Tank 8, 9, 13 and 14). The CP system is manufactured by Corrpower (Model

COYSE 50-34R with serial # CO11956). This unit is a 50 volt 34 ampere air-cooled rectifier unit

(numbered CP 3) and is mounted on the outside of the pumphouse on the northeast end of the secondary containment. The January 2017 report provided indicated that Tank # 8 is receiving cathodic protection based on NACE criterion. The rectifier, anode junction box, and tank junction box all are in satisfactory condition.

C. FINDINGS AND RECOMMENDATIONS

The tank is generally not in accordance with current military criteria for some of the tank design, appurtenances and piping configuration. Therefore, the recommendations are not meant to bring the tank into full compliance with UFC 3-460-01 or AW 78-24-27 standards but rather to identify these items for the owner/user’s planned upgrades, rehabilitation, and priority repairs. Mandatory repairs should be completed to assure compliance with industry standards, as well as federal or state jurisdictional requirements.

During this evaluation, the tank bottom was found to be in a generally serviceable condition, with no imminent risk to operation and overall integrity (See Section B.3 above for the result of the tank bottom NDT and recommendation). However, there were several deficiencies that were noted. These noted deficiencies are listed below in no particular order, with repair recommendations.

All repairs and modifications should be performed in accordance with API standard 653, UFC 3‐460‐01, DoD

Standard Design 78‐24‐27, and applicable UFGS specifications.

1. MANDATORY REPAIRS per API 653, UFC 3-460-01, or AW 78-24-27 Standards

Mandatory repairs represent items that require immediate attention, in order to prevent imminent risk to system operators, equipment integrity, or the adjacent environment. The tank should remain out of service until these repairs are completed.

No mandatory repairs were identified for this tank.

2. REQUIRED REPAIRS to Fully Comply with API 653 or Federal, State, and Local Codes

Required repairs represent items that should be addressed in a timely manner, in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment. These items are be required by API 653 or federal, state, and local codes.

a. Secondary Containment Cracks

OBSERVATION: Unsealed cracks were identified in the secondary containment wall (this includes areas that were previously sealed).

Code REFERENCE: 40 CFR Section 112.7(c) states that the entire secondary containment system, “including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system ... will not escape containment before cleanup occurs.”

§§112.8(c)(2) and 112.12(c)(2) state that diked areas must be “sufficiently impervious to contain oil.”

RECOMMENDATION: Repair all exposed cracks in the containment walls by grinding in a V‐shape pattern, with at least ¼‐inch width at the surface and a depth of at least ¼‐inch and sealing with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant (Quantity: 20 linear feet).

b. Secondary Containment Expansion Joint Sealant

OBSERVATION: There are areas of weathered and deteriorated sealant throughout at the expansion joints for the secondary containment wall.

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Remove the damaged joint sealant and install new backer rods and sealant within the containment. The sealant shall be adequate to accommodate a joint compression equal to 50 percent of the width of the joint. The backer rod shall be compressible rod stock of polyethylene foam, polyurethane foam, butyl rubber foam, or other flexible, non‐absorptive material, as recommended by the sealant manufacturer. Sealant shall conform to UFGS 07 92 00 Joint Sealant

(Quantity: 49 linear feet).

c. Secondary Containment Drain

OBSERVATION: The drain inlet and release valve did not pass the hydrostatic test (leaking inside the valve pit between the PVC to valve flange). The drain inlet passed with no measurable difference in water level after blocking the drain pipe with test plug. However, due to the breach in the inside of the valve pit (between the PVC to valve flange), the valve pit is not considered liquid tight. Valve pit has rain covers but standing water was noted in valve pit.

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Upgrade the concrete drain inlet as detailed in AW 78‐24‐27 Drawing CD.09

Detail 3 or similar. Use ductile iron piping in lieu of the PVC dike drain lines. At a minimum, repair the leaking flange joint and test the integrity of the valve pit to assure it is liquid tight. It may be practical to replace the drain valve since it does not operate properly (was stuck at the time of the inspection). A temporary plug was installed.

d. Secondary Containment Liner Penetration

OBSERVATION: The secondary containment PVC FML penetrations (CP/Leak Detection) and the abounded under bottom water draw-off pipe have deteriorated caulking and loose hose clamps.

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Reseal all PVC FML penetrations and secure hose clamps. See similar application over concrete in AW 78‐24‐27 Drawing CD.02 Detail 2.

e. Secondary Containment Wall Penetration

OBSERVATION: Pipe penetrates through the secondary containment wall without the use of adequate pipe sleeve/seal. Spray foam material used at some penetrations (Quantity: 4).

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Reseal all PVC FML penetrations and secure hose clamps. See AW 78‐24‐27

Drawing CD.08 Detail NA (CONCRETE WALL PENETRATION DETAIL)

Leak noted while packing the inlet pipe for hydro

f. Secondary Containment Wall Penetration (unsecured blind flange)

OBSERVATION: Pipe penetrating through the secondary containment has loose flange cover with four fasteners missing. This could result in a breach in the secondary containment wall.

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Secure flange and install all fasteners

g. Deteriorated Victaulic coupling (associated with tank 9)

OBSERVATION: All victaulic couplings for the fire suppression piping have deteriorated bolts. Several locations have completely failed victaulic couplings. This could result in a breach in the secondary containment since this pipe extends outside of the secondary containment and similar corrosion was noted on coupling fasteners outside of the dike. The section of the fire suppression piping is also routed underground outside of the dike and tightness of the piping is unknown.

Code REFERENCE: 40 CFR Section 112.7(c) (See reference from above)

RECOMMENDATION: Replace all deteriorated bolts, coupling and pipe. Fasteners shall be 316 SS.

h. Corrosion on piping and pipe supports

OBSERVATION: Piping and pipe supports within the tank secondary containment have moderate corrosion. Majority of the pipe supports have completely deteriorated.

Code REFERENCE: API RP 574 Section 7.4.14 (Contact Point Corrosion) API RP 574 Section 8.2

(Proper position and function of supports, hangers, and anchors).

RECOMMENDATION: Repair coating failure on piping. Replace deteriorated piping supports per AW

78‐24‐27 Drawing CD.13 Detail 1 and 2

Outside of the secondary containment

i. Corrosion and pitting on containment piping

OBSERVATION: Areas of pitting noted on product piping within the containment. A max pit depth of

0.190” was measured on an NPS 6 issue piping with remaining wall thickness of 0.090 inches.

Code REFERENCE: API RP 574 Section 7.4.14 (Crevice Corrosion). API RP 574 Section 10.1.6.3 (Loss in thickness)

RECOMMENDATION: Replace spools of ping that have significant piping and corrosion. It may be practical to conduct a detailed API STD 570 inspection of the containment piping to get an overall condition assessment. NDT tools such as guided wave examination can also be employed to get condition of inaccessible areas between pipe supports, sleeved piping, wrapped piping or through dike wall penetration. Guided wave examination is a screening tool used to inspect large sections of piping from a single test location.

j. Tank Grounding Lug

OBSERVATION: The tank grounding straps are bolted to the tank shell (mechanical joint on a coated interface) and have no reinforcement plates or grounding lug IAW AW 78‐24‐27 Drawing ED.02

Detail 2.

Code REFERENCE: AW 78‐24‐27 Drawing ED.02 Detail 2. (See also API 650 Section 5.8.11.3)

RECOMMENDATION: Exothermically weld the grounding cables to the lug and install reinforcement at the shell, in accordance with AW 78‐24‐27 Drawing ED.02 Detail 2. Note: If repairs are not done, the paint shall be removed from the grounding lug, to provide a better connection to ground (Quantity: 1 ground connections). Note the current edition of API STD 650 suggests maximum lug spacing of 100

ft. with minimum of four lugs.

k. Product Saver Tank (PST) Grounding

OBSERVATION: The Product Saver Tank is not grounded at the leg and does not have a vent installed in accordance with AW 78‐24‐27 Drawing D.13 Detail A1. The PST is a stainless steel tank with a top lid. The PST tank has no means of grounding.

Code REFERENCE: AW 78‐24‐27 Drawing D.13 Detail A1. In accordance with NFPA 30, paragraph

6.5.4, “All equipment such as tanks, machinery, and piping shall be designed and operated to prevent electrostatic ignitions. All metallic equipment where an ignitable mixture could be present shall be bonded or grounded. The bond or ground or both shall be physically applied or shall be inherently present by the nature of the installation.”

RECOMMENDATION: Install a ground cable and vent piping to the Product Saver Tank in accordance with AW 78‐24‐27 Drawing D.13 Detail 5 (Quantity: 1 ground, 1 vent pipe (1 ¼ NPS, 2‐feet high).

l. Tank sump

OBSERVATION: The tombstone patch plate welds in the sump and the sump corner welds inside the sump have coating failure and corrosion with weld undercut and lack of fill noted where coating has failed.

Code REFERENCE: According to API Standard 653, Paragraph 9.6.3 “Existing weld undercut deemed unacceptable based on suitability for service considerations shall be repaired by additional weld metal, or grinding, as appropriate.”

RECOMMENDATION: Repair the deteriorated welds on the tombstone patch plate and corner welds inside the sump. Repair weld undercut, lack of fill and coating failure noted at patch and corner sump welds. Alternatively install a new sump that conforms to API Standard 650 Section 5, paragraph 5.8.7 and AW 78‐24‐27 Drawing D.07 Detail 5. After repairing weld defects listed in API 653, Section 9.6, the repaired areas shall be examined in accordance with the requirements of API 653, Section 12.1.3.

m. Shell Manhole Cover with no Hinge or Davit Arm

OBSERVATION: The shell manhole covers are not equipped with a hinge or davit arm to facilitate the handling of the manhole cover plates.

Code REFERENCE: API STD 650 Section 5.8.3.5 states “Shell manhole covers shall have two handles.

Those covers weighing more than 34 kg (75 lb) shall be equipped with either a hinge or davit to facilitate the handling of the manhole cover plate. The davit support arm shall not be welded directly to the shell without a reinforcing plate.” Also AW 78‐24‐27 drawing D.10 detail 3

RECOMMENDATION: Install a shell manhole davit arm IAW with API STD 650 and AW 78‐24‐27 drawing D.10 detail 3. Note: AW 78-24-27 has manholes of 36 inches, 30 inch and 20 inch manholes are undersized. See UFC 3-460-01 Section 12-3.2 (Quantity: 3)

n. Shell Manhole Flange (Exterior corrosion) OBSERVATION: Coating failure and corrosion on 20 inch manhole flange.

Code REFERENCE: API STD 650 Section 5.7.5.2 and Table 5.3b

RECOMMENDATION: Arrest the corrosion by cleaning and coating the manhole flange. Alternatively consider future upgrade to the 36” manhole per UFC and AW7 8‐24‐27 drawing.

o. Interior Tank Coating

OBSERVATION: Minor to moderate coating failure (mostly holidays) was noted throughout the tank bottom, shell-to-bottom and sump. Bottom dry film thickness (DFT) readings typically ranged between 7 - 20 mils, with some areas near the shell-to-bottom and bottom lap welds having a high coating thickness in the range of 21 to 30 mils. The interior shell coating terminates approximately at

42 inches above the tank bottom.

Code REFERENCE: “Other products. Coat the floor, the underside of the fixed roof, and the bottom 40 inches (1000 mm) of the tank shell. Additional coating of up to 100 percent requires economic justification and Service Headquarters approval.” (UFC 3-460-01 Section 8-3.9(a)(2)).

RECOMMENDATION: Prepare the surface of the tank bottom and repair the entire coating IAW UFGS-

09 97 13.17.

p. IFR Panel corrosion

OBSERVATION: Several corrosion areas noted on top side of the IFR (largely due to galvanic corrosion between aluminum IFR and stainless steel grounding cable). There are several locations with 1 sq. in.

to 2 sq. in. corrosion spots with internal structure of the IFR visible.

Code REFERENCE: General maintenance/manufacturer instruction and API 653 Checklist item

(opening in seals that will permit vapor emissions) and API STD 653 Section 4.2.3

RECOMMENDATION: Clean and repair smaller pitting areas with polysulfide sealant. Replace IFR panels that have larger pitting areas. (five panels). A clear nylon covered stainless steel grounding cable can be installed to eliminate galvanic coupling between the stainless steel grounding cable and the thin aluminum sheet panels.

q. Standing water on IFR

OBSERVATION: Small amount of standing water was noted after heavy rain events on eight IFR panels, primarily near the center and south east end of tank. Additional investigation or testing may be required to determine the exact locations of water infiltration. There is minor caulking deterioration and signs of standing water on the geodesic dome roof panels. Inspection of the dome roof is limited to what is accessible from the platform.

Code REFERENCE: General maintenance/manufacturer instruction and API 653 Checklist item

(opening in seals that will permit vapor emissions)

RECOMMENDATION: Seal the top side of the geodesic dome roof as needed to eliminate water intrusion.

TYP for Small pitting Areas TYP for Large pitting Areas

Stainless steel IFR grounding cable

r. IFR Pipe Penetration Gaskets

OBSERVATION: The internal floating roof stilling wells penetration gaskets have deteriorated (four gaskets).

Code REFERENCE: General maintenance/ manufacturer instruction and API 653 Checklist item

(opening in seals that will permit vapor emissions)

RECOMMENDATION: Replace the gaskets. Gaskets inside the tank nozzles shall be non-asbestos, fuel resistant composition, or preformed type. ATG Well = 18" x 18" with NPS 8 pipe and Water Probe

Gauge Well = 18" x 18” with NPS 8 pipe.

s. Conduit, Junction Boxes, Fittings and Mounting Hardware

OBSERVATION: The conduits, junction boxes, fittings and mounting hardware within the secondary containment have deteriorated. This will not meet the Class 1, Division 1 rating requirements for hazardous locations.

Code REFERENCE: All wiring and fittings in a Class I location that is a bulk plant or terminal must comply with the applicable provisions of NEC Article 501 or Article 505 [515.7].

RECOMMENDATION: Replace all corrode/deteriorated conduits, junction boxes, fittings and mounting hardware. Secure loose caps on Junction boxes.

t. Top Platform grating not secured down

OBSERVATION: The stairway top platform does not have anchor/saddle clips

Code REFERENCE: OSHA and AW 78‐24‐27 Drawing D.11 Detail 1 “Grating shall be anchored with saddle clips”.

RECOMMENDATION: Install grating anchors.

3. RECOMMENDED REPAIRS to fully comply with UFC 3-460-01 & AW 78-24-27 Standards or 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. Tank Bottom Extension (Chime)

OBSERVATION: The foundation to chime interface is sealed. Minor sealant deterioration is present.

Code REFERENCE: Maintain a waterproof seal at the tank chime ring wall foundation interface (UFC 3-

460-03 Section 10.3.3).

RECOMMENDATION: Repair areas of failed sealant by applying a polysulfide mastic sealant caulking.

NOTE: Do not caulk the end (side) of the chime. See AW 78‐24‐27 Drawing D.04 Detail 3. Repair coating on the chime area. (Quantity: 12 linear feet).

b. Exterior Coating Failures on Tank, Appurtenances

OBSERVATION: Isolated coating failure on the exterior shell mostly above the stiffening ring. Similar isolated coating failure noted on the PST pump, HLV tubing support mounting brace, low level and high level sensor chambers. There is moderate coating failure on product piping within the secondary containment.

Code REFERENCE: UFC 3‐460‐01, Section 8‐3.10 and Section 9‐10

RECOMMENDATION: Mechanically clean and recoat areas of coating failure on the tank shell, piping, and appurtenances. Repairs shall be accomplished using an epoxy based coating system or equivalent.

c. Faded Tank Marking

OBSERVATION: No NFPA marking, no confined space marking (disregard the temporary confined space placards that were installed for tank cleaning and inspection project)

Code REFERENCE: Mark tanks with easily discernible painted numbers and letters indicating the following in addition to the requirements stated in MIL-STD-161: Tank number, Facility number, “No

Smoking” on class 1 tanks, and “Confined Space” on Roof Manhole/Ladder Hatch (UFC 3‐460‐01, Section 2‐18)

RECOMMENDATION: Replace the faded tank marking IAW NATO requirements. Install NFPA 704 marking and confined space marking. Install hold-off distance on roof.

d. Tank Electronic ATG and Water Probe

OBSERVATION: The tank’s Enraf (Model # 854) ATG is installed through an 8-inch aluminum stilling well. The stilling well is slotted. The Enraf system was not in working order at the time of the inspection. The water probe is not mounted over the sump and is installed via eight inch carbon steel well. The water probe is not installed over the tank bottom sump through a water probe well

(separate well).

Code REFERENCE: UFC 3-460-01 Section 8-8.3 (item p and s) and AW 78‐24‐27 Drawing D.07 Detail 3, 4 and 5)

RECOMMENDATION: Replace the ATG. Modify the stilling wells IAW with AW 78‐24‐27. Mounting plate welding per API STD 653 Section 9.10.3

e. Independent Low-Low Level Alarm

OBSERVATION: The tank is not equipped with an independent low-low level alarm. There is a low level alarm sensor installed on the side of the tank shell (see photo below).

Code REFERENCE: UFC 460 3-460-01 Table 8-1(k) and AW 78‐24‐27 Drawing D.12 Detail 1

RECOMMENDATION: Install an independent low-low level arm. The low-low level alarm switch should actuate 1 min before the IFR pan bottoms out when the pan legs are set at the low position.

f. Product Saver Tank (PST) Pump, Level Alarm OBSERVATION: The Product Saver Tank (PST) is not equipped with an electrical pump and does not have high level alarms. The existing diaphragm operated pump has moderate corrosion with deteriorated appurtenances (broken regulator, corroded air filter housing and corroded valve handle) Code REFERENCE: AW 78‐24‐27 Drawing D.13 Detail 5. IAW UFC 3-460-01 Section 3-6.6.7 “Mount permanently installed pumps on substantial foundations of reinforced concrete designed in accordance with Hydraulic Institute Standards.”

RECOMMENDATION: Consider replacement of existing system with new in accordance with AW 78-24-

27.

g. Internal ladder

OBSERVATION: There is no internal ladder to access the top of the floating roof. The IFR can only be accessed from the underside. (Existing stilling well configuration and underside of roof manhole location shown on photos)

Code REFERENCE: UFC 460 3-460-01 Table 8-1(h) and AW 78‐24‐27 Drawing D.08 Detail 2

RECOMMENDATION: Install the internal ladder (in accordance with OSHA criteria) for tanks of 5,000 gallons (19 000 L) or larger per UFC 460 3-460-01 Table 8-1(h) and AW 78‐24‐27 Drawing D.08

Detail 2

h. No sample gauge well

OBSERVATION: There is no manual sampling/gauging well.

Code REFERENCE: UFC 460 3-460-01 Table 8-1(s) and AW 78‐24‐27 Drawing D.07 Detail 2

RECOMMENDATION: Install a 10-inch roof nozzle and an aluminum, slotted stilling well that extends to within 3 inches of the bottom of the tank for gauging and sampling with a datum plate to establish a gauging zero point.

i. Double block and bleed valve missing tube

OBSERVATION: The product issue double block and bleed valve is missing the manual bleed valve goose neck tube. Coating, water and some corrosion was noted inside the differential thermal relief

(DTR) valves, and long term exposure to internal section of DTR valve could cause the system to not perform as designed.

Code REFERENCE: General maintenance/manufacturer drawing.

RECOMMENDATION: Reinstall the goose neck tube to prevent drainage of body liquid and to prevent water and debris from entering the DTR valve. The tube shall be above the highest point of the body cavity. A steel plug can also be used to prevent water intrusion.

j. Product Piping Label Marking

OBSERVATION: The majority of the secondary containment piping have product pipe markings. Faded marking were noted.

Code REFERENCE: AW 78‐24‐27 Drawing CD.13 Detail x. (refer to MIL-STD-161G for correct fuel type)

RECOMMENDATION: Reapply product piping marking.

k. Personnel static electric discharge

OBSERVATION: The tank is not equipped with a copper grounding bar for personnel static electric discharge (typically required by military criteria).

Code REFERENCE: UFC 3-460-03 Section 2-3.21 and AW 78‐24‐27 Drawing D.11 Detail 4

RECOMMENDATION: Install a copper grounding bar for personnel static electric discharge at the base of the circumferential stairway

l. AST Exterior Fire Protection Water Systems

OBSERVATION: The tank does not appear to meet the equipment requirement for AST exterior fire protection system. The stand post mounted water jet monitor was noted along the facility fence line northeast corner of the dike.

Code REFERENCE: UFC 3-460-03 Section 2-15.2.1

RECOMMENDATION: Install additional services for the tank exterior fire protection water systems IAW

UFC 3-460-01 Section 2-15.2.1 (fire protection water mains, hydrants, valves, pumps, and application devices outside of dike) to control brush and grass fires and cooling of storage tanks in the event of a fire exposure.

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 BOTTOM SERVICE LIFE EVALUATION

A.2 SHELL SERVICE LIFE EVALUATION

A.3 SHELL SETTLEMENT EVALUATION

A.4 ULTRASONIC UT DATA

A.5 CONTAINMENT LAYOUT DRAWING

A.6 BOTTOM LAYOUT DRAWING

A.7 SHELL LAYOUT DRAWING

A.9 OSHA ACCESS STRUCTURE REPORT

Benyam Typewritten Text

Where:

MRT = minimum remaining thickness at the end of the in-service period of operation, in inches.

O r = in-service interval of operation (years to next internal inspection), in years; not to exceed that allowed by 6.4.2.

t o = original plate thickness, in inches.

RT bc = minimum remaining thickness from bottom side corrosion after repairs, in inches.

Rt ip = minimum remaining thickness from internal corrosion after repairs, in inches.

StP r = maximum rate of corrosion not repaired on the top side, in inches per year. StP r =

0 for coated areas of the bottom. The expected service life of the coating must equal or exceed O r to use StP r = 0.

UP r = maximum rate of corrosion on the bottom, in inches per year. To calculate the corrosion rate, use the minimum remaining thicknesses after repairs. Assume a linear rate based on the age of the tanks. UP r = 0 for areas that have effective cathodic protection.

MRT

(inches)

0.1

0.05

0.05

Note: For areas of a bottom that have been scanned by the magnetic flux leakage (or exclusion) process, and do not have effective cathodic protection, the thickness used for calculating UPr must be the lesser of the MFL threshold or the minimum thickness of corrosion areas that are not repaired. The MFL threshold is defined as the minimum remaining thickness to be detected in the areas inspected. The MFL unit used for scanning the bottom does not have a threshold set point. This unit visually displays all anomalies. The confidence level of this unit diminishes greatly for underside pitting/corrosion that is less than 0.04 inches in depth, based on company experience.

Areas of bottom side corrosion that are repaired should be evaluated with the corrosion rate for the repaired area unless the cause of corrosion has been removed. The evaluation is done by using the corrosion rate of the repaired area for UP r , and adding the patch plate (if used) thickness to the term "minimum of RT bc or RT ip ".

NOTE: The engineering data used to calculate the in-service interval of operation (O r ) assumes the tank remains in the same service and all corrosion rates remain constant.

Bottom Service Life Evaluation

Tank Bottom/Foundation Design

Tank bottom/foundation design with no means for detection and containment of bottom leak

Tank bottom/foundation design with means to provide detection and containment of bottom leak

Applied tank bottom reinforced lining, > 0.05 in. thick, in accordance with API RP 652

MRT =

Or = to RTip RTbc

Benyam Typewritten Text

Benyam Typewritten Text

Benyam

Present Condition:

1) In-Service Interval of Operation (years to next internal inspection)

Yes Yes No Yes

MRT = 0.1 inches

RT ip = 0 inches

RT bc 0.322 inches

StP r = 0…