Attachment J1 - Irwin-Fac 7706DT (Tank 7706DT)-FINAL-2020.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service External Inspection Report

Fort Irwin; Fort Irwin, California Facility Number 7706

Tank Number 7706

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

(USACE POL-MCX)

December 6, 2019

API 653 In-Service Inspection (External Inspection) Fort Irwin, California (Facility 7706)

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 External Visual 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

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 BOTTOM SERVICE LIFE EVALUATION (N/A – Not Performed)

A.2 SHELL SERVICE LIFE EVALUATION (N/A – Not Performed)

A.3 SHELL SETTLEMENT EVALUATION (N/A – Not Performed)

A.4 ULTRASONIC UT DATA (N/A – Not Performed)

A.5 CONTAINMENT LAYOUT DRAWING

A.6 BOTTOM LAYOUT DRAWING (N/A – Not Performed)

A.7 SHELL LAYOUT DRAWING

A.8 ROOF LAYOUT DRAWING

A.9 OSHA ACCESS STRUCTURE REPORT

APPENDIX B: 3-D DOCUMENTATION AND ANALYSIS

APPENDIX C: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX D: 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 visual external inspection, in-service, of Tank 7706 (Facility 7706) at Fort Irwin, California was completed on November 20, 2019. The tank Inspection was conducted per applicable industry standards (API 653), NFPA 30, and in compliance with 40 CFR 112, UFC 3-460-01, UFC 3-460-03, and any other applicable federal, state, local, service or host nation requirements. All tank appurtenances that are required are documented along with all required appurtenances that aren’t present. Alarms, automatic tank gauge equipment, and all tank appurtenances were tested or verified to be in operation when present. The secondary containment was also visually inspected and assessed for ability to contain the entire contents of the tank in the event of catastrophic failure. Additionally, the secondary containment was assessed for cracks, settlement, and deterioration.

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

a. None.

REQUIRED REPAIRS to Fully Comply with API 653, Federal, State, or Local Codes:

a. The secondary containment basin has approximately 75 Linear Feet (LF) of unsealed cracks).

b. The concrete secondary containment berm has approximately 132 LF of minor to moderate cracks on the interior section of the wall.

c. The concrete secondary containment berm walkway has approximately 25 LF of minor to moderate cracks on the top section of berm.

d. The concrete secondary containment basin wall has one area of spalling approximately 24” x 10”.

e. The concrete secondary containment berm walkway has approximately 5 LF of minor deteriorated sealant on the top section of berm.

f. The shell manhole cover is not equipped with hinges or davit arms to facilitate the handling of the manhole cover plates.

g. The manhole reinforcement plate to shell-to-bottom weld spacing is not in accordance with API

STD 650. The required weld spacing is three inches measured toe-to-toe of the welds. The current measurement is approximately 2 inches.

h. The manhole reinforcement plate-to-shell vertical weld spacing is not in accordance with API STD

650. The required weld spacing is six inches measured toe-to-toe of the welds. The current measurement is approximately 0 inches.

i. The tank is equipped with two roof mounted Pressure Vacuum (P/V) vents. One P/V vent is missing a screen on the vacuum side of the Varec Fig 2010 device.

j. Both P/V vents are equipped with a flame arrestor. The flame arrestor may prevent proper function of these devices.

k. The tank is equipped with a 24 inch emergency vent (Manufactured by Varec). The emergency vent is stuck shut and does not appear to work.

l. The tank grounding straps are bolted on a coated mounted clip and have no reinforcement plates or grounding lugs.

m. The ¾” shell nozzle is fitted with a brass valve (low melting point).

n. The 4” Vapor recovery line from Tank 7706 is equipped with a 2” brass valve and fittings (low melting point).

o. The tank roof access hatches are not equipped with a confined space marking.

p. Fabricated plate used as a blind flange on the NPS 3 low suction nozzle (not rated per ASME B16.5).

q. The issue line is not equipped with a TRV and bypass piping.

r. There is moderate staining on the six inch product issue DBB valve.

s. The Product Saver Tank is not grounded at the leg.

t. The secondary containment is not equipped with an access stairway.

u. There is abandoned piping with double wall casing inside the secondary containment basin. These pipes were the original piping to and from the tank. The carrier piping are currently filled with concrete; however, it is not clear if the casing is also filled with concrete.

v. The tank is not equipped with a personnel static grounding copper bar per AW 78-24-27.

w. The raised foundation has circumferential cracking around the entire circumference.

x. There are moderate spalling and exposed rebar on the raised foundation.

y. The tank is equipped with a Mechanical Tape Gauge (MTG). The display is also faded on the MTG.

The Bump Checker knob is loose.

z. The tank is equipped with multiple stilling wells, but the ENRAF level probe and Vito water probe are not mounted inside a well. Note: both probes are in the same flange.

aa. The tank does not have two scaffold cable supports installed on the fixed roof.

bb. There is no “hold off distance” stenciled or painted at the manual tank gauge/sample hatch on the roof.

cc. Product staining was noted on the flush deck cleanout.

dd. Missing label and inconsistent marking on the multiple point liquid level control system.

ee. The ½ stainless steel (SS) tubing from the HLV to HLV Float Pilot has a section of unsupported tubing near the tank foundation (adjacent to the shut-off valve).

ff. The jam nut on the 55F Pressure Relief Control set screw is not locked in potion.

gg. The tank piping within the dike does not all have yellow bands/product symbols and directional arrows.

hh. There is no seal-off provided for the Product Saver Tank (PST) pump conduit at the secondary containment exit area.

ii. The tank foundation presents a 18 inch step up before getting to the circumferential stairway. This is not per OSHA requirements for consistent dimensions of stairway.

jj. The explosion proof conduit sealing fitting is missing the sealing compounds on multiple point liquid level control system. This will not meet the Class 1, Division 2 rating requirements for hazardous locations.

kk. Several of the Cathodic Protection (CP) soil access plugs were loosely fitted on the basin floor ports.

ll. The bulbs on the multiple point liquid level control system used for independent level alarm panel did not all light up when tested.

mm. The ENRAF ATG float and VITO water probe share a common roof nozzle. Possible entanglement could damage the system and provide inaccurate measurements

RECOMMENDED REPAIRS TO FULLY COMPLY WITH UFC 3-460-01, AW 78-24-27 Standards or as Part of Regular Maintenance:

a. The contrast on the ENFRAF TSI is too dark to properly read the tank level.

b. The ½ stainless steel (SS) tubing, the galvanized unistrut, and cast iron basin drain cover are periodically submerged underwater when there is precipitation.

c. There is near total coating failure on the receipt pipping within the dike.

d. There is near total coating failure on the receipt pipping DBB valve with poorly adhered coating.

e. The bend radius on the flex conduit on the Product Saver Tank is over the manufacturer’s recommended radius.

f. There are four abandoned pipes that penetrate the secondary containment basin with moderate coating failure and corrosion

INSPECTION DATE

API In-Service (External) Inspection Date: 20 November 2019

Equipment (s) Used:

Ultrasonic Thickness (A-scan/B-scan) Testing Manufacturer: N/A Model: N/A Go+ Calibration Methods Used: N/A

Tank Bottom Surveying Manufacturer: N/A Model: N/A Calibration Methods Used: N/A

Tank Shell Surveying Manufacturer: N/A Model: N/A Calibration Methods Used: N/A

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: 8 December 2006 API In-Service (External) Inspection Date: 2 February 2015 Alteration/Repairs Completed: 2012

New NPS 8 and NPS 4 Aluminum Poles and Miscellaneous Repairs

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

Routine In-service Inspections (API 653-6.3.1): Monthly (owner/operator personnel) External (Visual) Inspection (API 653-6.3.2): 20 November 2024 Ultrasonic Thickness Inspection (API 653 -6.3.3): 2 February 2030* Internal Inspection** (API 653 – 6.4): 8 December 2026*

*Schedule based on Previous Inspection reports.

**UFC 3-460-03 Indicates Internal (out-of-service API 653) inspection every ten (10) years

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

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S. Army

Location Fort Irwin, California

Facility Number 7706

Tank Number 7706

State / Country California/USA

City Barstow

Inspection Date 20 November 2019

Tank Manufacturer Pitt-Des Moines, Inc. (Erected by: Hydrostorage, Inc.)

Design Standard Unknown (Not Listed on Data Plate)

Date of Construction 1986

Tank Contents Diesel

Tank Serial Number None

Tank Diameter 25 Feet

Shell Height 30 Feet

Product Height 29 Feet

Tank Capacity 2,380 BBL (100,000 Gallon)

Foundation Concrete Ringwall

Construction

Bottom Lap‐Welded (Cone‐Down)***

Shell Butt‐Welded (Cylindrical)

Floating Roof None

Fixed Roof Lap Welded (Cone-Up)

Material

Bottom Carbon Steel (unknown specification)

Shell Carbon Steel (unknown specification)

Floating Roof N/A

Fixed Roof Carbon Steel (unknown specification)

Cathodic Protection Impressed Current

Interior Coating System N/A

Exterior Coating System Epoxy with a polyurethane top (Tan)

Level Gauging ENRAF Electronic Tank Gauge with Varec 2500 Mechanical Tape Gauge

Overfill Protection Hydraulically Operated High Level Shut-Off Valve with Float (Set at 27.92 Feet)

Piping Receipt 6" Carbon Steel

Issue 6” Carbon Steel

Low Suction 3" Carbon Steel

Water Draw-Off 2"/1" Carbon Steel/Stainless Steel

Level Alarms (ATG Set Points)

Low‐Level Alarm: 3.000 Feet Low‐Low Level Alarm: 1.500 Feet High‐Level Alarm: 25.714 Feet High‐High Level Alarm: 26.885 Feet High‐Level Control Shutoff: 27.92 Feet

Type of Internal Floating Roof

None

***Per previous internal inspection Report

A. GENERAL PROJECT INFORMATION

1. API 653 External Visual Inspection

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

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

An API Standard 653 visual external inspection, in-service, was performed for Tank 7706 (Facility

7706).

2. Site Information

On November 20, 2019 InterSpec, LLC under contract to Argus Consulting Inc. performed a visual external inspection, in-service, of Tank 7706 (Facility 7706) located at Fort Irwin, California. Fort Irwin is part of the U.S. Army FORSCOM and provides realistic joint and combined arms training exercises to units prior to deployment. Fort Irwin is located approximately 37 miles northeast of Barstow, California in the High Mojave Desert midway between Las Vegas, Nevada and Los Angeles, California.

Tank 7706 (Facility 7706) is used as an aboveground fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 7706 (Facility 7706) is a nominal 2,380 BBL (100,000 Gallon), 25‐foot diameter by 30‐foot tall, diesel fuel, aboveground vertical storage tank. The tank was fabricated by Pitt-Des Moines, Inc. and erected by Hydrostorage, Inc. in 1986 to an unspecified standard. There was repairs/alterations performed on this tank, and it included installation of a new NPS 8 and NPS 4 aluminum poles and miscellaneous repairs that were completed in 2012 by CAPE.

2. Tank Foundation

The tank sits on a concrete ringwall foundation that is elevated approximately thirteen (13) to eighteen

(18) inches above the secondary containment floor. The foundation is not equipped with a leak detection (tell‐tale) system that extends through the ringwall. 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 vegetation was present, but there was minor spalling and exposed reinforcement bars. The bottom plate extension (chime) is sealed and is in satisfactory condition. The foundation has circumferential cracking around the entire circumference. The cracking starts at approximately six inches above the basin and loops down to about one inch above the basin. There are several shrinkage cracks, spider cracks, and crazing type cracks throughout the foundation.

3. Tank Bottom

The tank bottom was not inspected during this inspection cycle. Accessible sections of the bottom projection and exterior shell-to-bottom welds were visually inspected.

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 three (3) courses. Visually evaluated the shell for plumbness, roundness, peaking, and banding; all of which were appear to be within the allowable tolerances of the API Standard 653. Visually inspected the exterior of the shell. Inspected the coating for dis-bonding, adhesion, deterioration, and discoloration. The tank shell is equipped with two manholes that are 180 degrees apart and are both sized as a 30" opening. The tank is equipped with shell mounted low-low level alarm, low level alarm, high level alarm, high-high level alarms, as well as a high-level shut-off.

5. Tank Appurtenances

a. Internal Floating Roof

N/A

b. Geodesic Dome Roof

N/A

c. Gauging

The tank’s Enraf (Model # UIAC854M21F2*CDZ) ATG is installed through a 6-inch aluminum stilling well using an 8-inch roof nozzle. The transmitter outputs the tank level to a continuous electronic tank monitoring system (FuelsManager Software) manufactured by

Varec. The tank is also equipped with a Model 977 Tank Side Indicator (TSI) that is mounted at the base of the circumferential stairway. The ATG system and software were in operation at the time of the inspection. The tank is equipped with a float and tape type Mechanical

Tape Gauge (MTG) manufactured by Varec (Model 2500). The overall general conditions of the tank gauging systems are satisfactory with some exceptions. The MTG appears to be out of calibration. At the time of the inspection, the MTG was indicating a different tank product level compared to the ATG. MTG reading = 13’ 2-6/16” and ATG reading = 12’ 7-15/16”. The display is faded on the MTG, and the bump checker knob is loose.

d. Level Alarms

The high-high and high level sensors are mounted on the shell and are accessible via the circumferential mounted stairway. Both high and high-high level sensors use the same float switch chamber. The tank is also equipped with low and low-low level sensors that are mounted in an individual chamber. The High-High Level Sensor (HHLS), High Level Sensor

(HLS), Low-Low Level Sensor (LLLS) and the Low Level Sensor (LLS) output to a multiple point liquid level control system display located southwest of the secondary containment area. The tank is also equipped with a high liquid level shut-off valve (HLV) that is actuated by a shell mounted HLV float pilot. Alarms, horns, and the associated indictor system were tested during this inspection. The facility also completed facility wide preventive maintenance testing of the alarms and ATG system on 10/17/2019. The overall general conditions of the level alarm are satisfactory (with some exception – See Section C).

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 2" angle iron handrails and steel plate threads with non-slip profile. The overall general condition of the stairs and platform are satisfactory (with some exceptions – See Section C).

f. Grounding and Bonding

There are three grounding cables connected to the tank’s anchor chair with one rectifier lead structural wire also attached to the anchor chair. A copper grounding bar for personnel static electric discharge is not mounted on the handrail (typically required by military criteria).

6. Tank Coating

The tank shell, bottom projection, roof, stairway, handrails, piping, and appurtenances are coated. The exterior tank coating is an epoxy with a polyurethane top coat (tan in color) with an unknown completion date. There is little to minor coating failure on the tank shell, with minor coating failure on the appurtenances, and roof plates. There is a total coating failure on the receipt piping.

7. Tank Piping System

The fuel is received through 6-inch carbon steel piping with a CLA Val and DBB valve at the tank. The product is issued through 6-inch carbon steel piping. Other auxiliary piping for the water draw (NPS 2) and low suction (NPS 3) are installed. The NPS 2 water draw reduces to NPS 1 and is attached to a

Product Saver Tank (PST). The low suction nozzle is blanked with a blind flange. Inspected and evaluated each tank nozzle in accordance with API Standards 650 and 653. Identified the type and use of each shell nozzle on all accessible shell nozzles. Evaluated all nozzles and reinforcement plates for leaks and corrosion.

8. Fire Protection System

None

9. Secondary Containment

The tank sits inside a concrete secondary containment basin with concrete berm walls. The overall dimensions of the secondary containment is 60 feet x 60 feet (basin footprint), with a sloped berm and a vertical height of 51.5 inches. The secondary containment is equipped with an 8" PVC drain pipe with a 32-inch drain area inlet. A drain valve is located on the berm wall and is operated with an extension pole. The valve drain pole was available at the time of the inspection.

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 and are documented in the secondary containment layout. An approximate total of 75 linear feet of cracks in the secondary containment basin were identified. An additional 132 linear feet of cracks were located on the berm walls and were classified as minor to moderate in crack appearance. The concrete secondary containment berm walkway has approximately

25 linear feet of minor to moderate cracks on the top section of the berm. Hairline cracks and cracks on top of the walking path 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). The sealant for the secondary containment concrete floor/interior wall expansion and slab joints appear to be in good serviceable condition with only minor deterioration identified. The concrete secondary containment walkway has approximately 5 linear feet of minor deteriorated sealant on the top section of berm. One are of spalling measuring approximately 24-inches by 10-inches was identified on the berm wall (south side). The secondary containment is otherwise in mostly satisfactory mechanical 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 with approximately 150,800 gallons of containment capacity (151%). 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. The secondary containment is equipped with a lockable secondary containment valve post indicator.

10. Cathodic Protection

An air-cooled impressed current Cathodic Protection (CP) system is installed on this tank which is serving the tank bottom for both Tank 7706 and Tank 7708. The rectifier was installed in 2010 and is located on the northwest side of the tank berm. The CP system is manufactured by Corrpro (Model

ADAI with Serial # 105199). This unit is an 80 volt 40 ampere air-cooled rectifier unit. The CP system is listed as having a five direction bored anode system with mixed metal oxide anode wires configured in beneath the tank bottom. The CP is provided with a VIP+ Remote Monitoring Unit (RMU) manufactured by Elecsys.

At the time of the inspection, the rectifier was powered on and in serviceable operation condition. Base personnel performed the required testing and data logging. The March 2019 report provided indicated that this tank 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 appurtenance 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 planed 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 was found to be in a generally serviceable condition, with no imminent risk to operation and overall integrity. 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 on this tank

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

Short-Term Repairs that directly relate to the long-term preservation of the assets. Short-term repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment. These items may be required by Federal, State, and Local Codes or by Military Criteria.

a. Secondary Containment Basin Cracks

OBSERVATION: The secondary containment basin has approximately 75 Linear Feet (LF) of unsealed cracks).

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 secondary containment basin.

b. Secondary Containment Wall Cracks (Interior Wall)

OBSERVATION: The concrete secondary containment berm has approximately 132 LF of minor to moderate cracks on the interior section of the wall.

CODE REFERENCE: 40 CFR Section 112.7(c) (See above)

RECOMMENDATION: Repair all exposed cracks in the secondary containment berm.

c. Secondary Containment Walk way Cracks (Top of Berm)

OBSERVATION: The concrete secondary containment berm walkway has approximately 25 LF of minor to moderate cracks on the top section of berm.

CODE REFERENCE: 40 CFR Section 112.7(c) (See above) and good engineer/maintenance practice.

RECOMMENDATION: Repair all exposed cracks in the secondary containment berm.

d. Secondary Containment Wall Spalling (Interior Wall)

OBSERVATION: The concrete secondary containment basin wall has one area of spalling approximately 24” x 10”.

RECOMMENDATION: Repair the spalling area in the secondary containment berm

e. Secondary Containment Walk way Sealant deterioration (Top of Berm)

OBSERVATION: The concrete secondary containment berm walkway has approximately 5 LF of minor deteriorated sealant on the top section of berm.

RECOMMENDATION: Repair all deteriorated sealant in the secondary containment berm.

f. Shell Manhole Covers with No Hinges or Davit Arms

OBSERVATION: The shell manhole cover is not equipped with hinges or davit arms 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 shell manhole davit arms in accordance with API STD 650 and AW

78‐24‐27 Drawing D.10 Detail 3

g. Manhole Reinforcement Weld Spacing (Horizontal)

OBSERVATION: The manhole reinforcement plate to shell-to-bottom weld spacing is not in accordance with API STD 650. The required weld spacing is three inches measured toe-to-toe of the welds. The current measurement is approximately 2 inches.

CODE REFERENCE: API STD 650 Section 5.7.3 (Figure 5.6 - Minimum Weld Requirements for Openings in Shells).

RECOMMENDATION: Modify the reinforcement pad of the shell manhole in accordance with API STD

653 Section 9.7. Note: Magnetic particle test all nozzle welds as an alternative to repair in accordance with API STD 653 Section 4.3.9.1. This test requires coating removal. It is suggested to repair the weld spacing in lieu of testing to prevent repeated questions of any previous magnetic particle testing during future inspections.

h. Manhole Reinforcement Weld Spacing (Vertical)

OBSERVATION: The manhole reinforcement plate-to-shell vertical weld spacing is not in accordance with API STD 650. The required weld spacing is six inches measured toe-to-toe of the welds. The current measurement is approximately 0 inches.

CODE REFERENCE: API STD 650 Section 5.7.3 (Same as above)

RECOMMENDATION: Modify the reinforcement pad of the shell manhole in accordance with API STD

653 Section 9.7. Note: Magnetic particle test all nozzle welds as an alternative to repair in accordance with API STD 653 Section 4.3.9.1. This test requires coating removal. It is suggested to repair the weld spacing in lieu of testing to prevent repeated questions of any previous magnetic particle testing during future inspections.

i. Pressure Vacuum (P/V) Vents Missing Screens OBSERVATION: The tank is equipped with two roof mounted Pressure Vacuum (P/V) vents. One P/V vent is missing a screen on the vacuum side of the Varec Fig 2010 device.

CODE REFERENCE: In accordance with NFPA 30, paragraph 21.8.6, “Storage tanks and their appurtenances, including normal vents, emergency vents, overfill prevention devices, and related devices, shall be inspected and maintained to ensure that they function as intended in accordance with written procedures.”

RECOMMENDATION: Install screens on the P/V Vent or install a new P/V vent.

j. Pressure Vacuum (P/V) Vents With Flame Arrestors OBSERVATION: Both P/V vents are equipped with a flame arrestor. The flame arrestor may prevent proper function of these devices.

CODE REFERENCE: UFC 3-460-01 Table 8-1 (o) “Do not use flame arrestors unless required by host-nation and/or NATO regulations.”

RECOMMENDATION: Remove the flame arrestors.

k. Emergency Vent Is Stuck OBSERVATION: The tank is equipped with a 24 inch emergency vent (Manufactured by Varec). The emergency vent is stuck shut and does not appear to work.

CODE REFERENCE: In accordance with NFPA 30-22.7.1.1, “Every aboveground storage tank shall have emergency relief venting in the form of construction or a device or devices that will relieve excessive internal pressure caused by an exposure to fire.” The tank design condition is unknown, and the existing tank does not confirm to API Std. 650 for frangible-roof design. (A roof mounted emergency venting device may be required to meet NFPA 30.)

RECOMMENDATION: Repair or replace the emergency vent.

l. Storage Tank Grounding Lug Attachments

OBSERVATION: The tank grounding straps are bolted on a coated mounted clip and have no reinforcement plates or grounding lugs installed as shown in AW 78‐24‐27 Drawing ED.02 Detail 2.

CODE REFERENCE: AW 78‐24‐27 Drawing ED.02 Detail 2. (See also API STD 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 elected not to be done, the paint should be removed where the cable bolts to the lug to provide a better connection to the ground.

m. Low Melting Point Material (3/4” Nozzle)

OBSERVATION: The ¾” shell nozzle is fitted with a brass valve (low melting point). Low melting point materials cannot be used with storage tanks within a diked area or drainage path of a tank storing a

Class I, Class II, or Class IIIA liquid.

CODE REFERENCE: In accordance with NFPA 30, Section 27.4.4, Note: Low melting point material cannot be used below the normal operating liquid level of a tank within a dike or remote impounding area, for Class I, Class II or Class IIIA liquids.

RECOMMENDATION: Replace the brass valve with a carbon steel valve.

n. Low Melting Point Material (4” Pipe from Tank 7706)

OBSERVATION: The 4” Vapor recovery line from Tank 7706 is equipped with a 2” brass valve and fittings. Low melting point materials cannot be used with storage tanks within a diked area or drainage path of a tank storing a Class I, Class II, or Class IIIA liquid.

CODE REFERENCE: In accordance with NFPA 30, Section 27.4.4, Note: Low melting point material cannot be used below the normal operating liquid level of a tank within a dike or remote impounding area, for Class I, Class II or Class IIIA liquids.

RECOMMENDATION: Replace the brass valve with a carbon steel valve (future upgrades should consider a water draw off system per AW 78-24-27).

o. No Confined Space Markings at Roof Manholes

OBSERVATION: The tank roof access hatches are not equipped with a confined space marking.

CODE REFERENCE: In accordance with OSHA Regulation 29 CFR 1910.146(c)(2), “If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. NOTE: A sign reading DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER or using other similar language would satisfy the requirement for a sign.”

RECOMMENDATION: Install confined space markings on all tank entry points.

p. Nonstandard Fittings (Flange)

OBSERVATION: A fabricated plate is used as a blind flange on the NPS 3 low suction nozzle (not rated per ASME B16.5).

CODE REFERENCE: API 650 4.6.1.2 plate material used for nozzle flanges shall have physical properties better than or equal to those required by ASME B16.5.

RECOMMENDATION: Install a blind flange rated per ASME B16.5 or a flanged plate that meets the minimum thickness given in table 5.8b.

q. No Thermal Relief Valve (TRV)/Bypass on Issue Line (Receipt Line TRV not Current Standard)

OBSERVATION: The issue line is not equipped with a TRV and bypass piping. The receipt TRV is not per current design standard (stainless steel piping).

CODE REFERENCE: UFC 3‐460‐03 paragraph 6‐6.3.1 (E), UFC 3‐460‐01 paragraph 9‐3.5.1

RECOMMENDATION: Install TRV piping designed in accordance with UFC. Have the valves calibrated annually and post a sticker on the valve indicating when calibration was performed.

r. Product Staining on NPS 6 Issue DBB Valve

OBSERVATION: There is moderate staining on the six inch product issue DBB valve.

CODE REFERENCE: Part of regular maintenance (NFPA 30, paragraph 27.3.2)

RECOMMENDATION: Disassemble and repair the staining at the threaded fitting (future upgrades with welded and flanged fittings)

s. Product Saver Tank (PST) Grounding

OBSERVATION: The Product Saver Tank is not grounded at the leg.

CODE REFERENCE: 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.” Additionally, see AW 78‐24‐27 Drawing D.13 Detail 5.

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).

t. Secondary Containment Access Stairway

OBSERVATION: The secondary containment is not equipped with an access stairway. The secondary containment consists of a sloped dike berm.

CODE REFERENCE: UFC 3-460-01 paragraph 8-14.8 recommends providing “enough access locations for safe emergency egress and for normal operation.”

RECOMMENDATION: Install an access staircase.

u. Secondary Containment Openings and Penetrations OBSERVATION: There is abandoned piping with double wall casing inside the secondary containment basin. These pipes were the original piping to and from the tank. The carrier piping are currently filled with concrete; however, it is not clear if the casing is also filled with concrete. There are open

¾” plugs on the casing, and these could be a potential breach within the secondary containment basin.

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: Seal-off all open ports on the abandoned receipt and issue piping inside the secondary containment basin.

v. Personnel Static Electric Discharge

OBSERVATION: The tank is not equipped with a personnel static grounding copper bar per AW 78-24-

27.

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.

w. Foundation Cracks

OBSERVATION: The raised foundation has circumferential cracking around the entire circumference.

There are several shrinkage cracks, spider cracks, and crazing type cracks throughout the foundation.

CODE REFERENCE: Inspect visible components of tank foundations for signs of erosion due to heavy rains, wash-down, etc. and repaired as necessary. Also inspect tank foundations for structural cracks, signs of settlement, spalling, or general deterioration. Remove vegetation found around the tank foundation. (UFC 3-460-03 Section 8-4.3.1).

RECOMMENDATION: Repair all exposed large cracks in the foundation. The rest of the foundation should be resurfaced or repaired using a concrete coating system to prevent water intrusion in to the rebar.

x. Spalling and Exposed Reinforcement Bar

OBSERVATION: There are moderate spalling and exposed rebar on the raised foundation; four locations (approx. 70 sq. in. area total).

CODE REFERENCE: UFC 3-460-03 6-11.1.1, “Check for cracks in the concrete and check piping penetrations through the pit wall or bottom to ensure that the mechanical seals and boot seals are in good working condition and are allowing no seepage of water into the pits. Make note of the cracks in the concrete and schedule maintenance as necessary.”

RECOMMENDATION: Repair the spalling and exposed rebar.

y. Mechanical Tape Gauge Faded Level Indictor Dial/Bump Check Knob

OBSERVATION: The tank is equipped with a Mechanical Tape Gauge (MTG). The display is also faded on the MTG. The Bump Checker knob is loose. MTG was indicating a different tank product level compared to the ATG. MTG reading = 13’ 2-6/16” and ATG reading = 12’ 7-15/16”.

CODE REFERENCE: UFC 3‐460‐01 Table 8‐1 (q).

RECOMMENDATION: Repair MTG and calibrate the mechanical tape gauge.

z. The ENRAF Level Probe and Water Probe (No Well)

OBSERVATION: The tank is equipped with multiple stilling wells, but the ENRAF level probe and Vito water probe are not mounted inside a well. Note: both probes are in the same flange.

CODE REFERENCE: UFC 3-460-01 Table 8-1 (y) and item (w)

RECOMMENDATION: Relocate the ENRAF ATG and water probe to the two separate wells mounted on the tank.

aa. No Scaffold Cable Supports

OBSERVATION: The tank does not have two scaffold cable supports installed on the fixed roof in accordance with UFC 3-460-01 and API STD 650.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (jj) and API STD 650.

RECOMMENDATION: Install two scaffold cable supports in accordance with UFC 3-460-01 Table 8-1

(jj) and API STD 650 (Quantity: 2).

bb. Hold‐Off Distance OBSERVATION: There is no “hold off distance” stenciled or painted at the manual tank gauge/sample hatch on the roof.

CODE REFERENCE: General maintenance/API STD 653 Checklist Item (C.1.5.1 (d) ‐ check for marker and tab stating hold‐off distance).

RECOMMENDATION: Stencil or paint the “hold off distance” at the manual tank gauge hatch.

cc. Product Staining on Flush Deck Cleanout OBSERVATION: Product staining was noted on the flush deck cleanout. The majority of the staining is noted at the bottom of the cleanout and around the fasteners.

CODE REFERENCE: API 650 5.7.1.9 “The flange facing shall be suitable for the gasket and bolting employed. Gaskets shall be selected to meet the service environment so that the required seating load is compatible with the flange rating and facing, the strength of the flange, and its bolting.”

RECOMMENDATION: Clean and monitor nozzles for any indication of continued staining. Replace the gasket and bolting fasteners at the next maintenance or next out of service inspection outage

dd. Missing Label and Inconsistent (Alarm Indicator Light Positioning) OBSERVATION: The tank is equipped with a multiple point liquid level control system to display the high and low level alarms. The low-low level indicator identification marking is missing on the display panel. Note: the panel displays the HHLA, HLA, LLA, and LLLA from right to left for Tanks

7706 and 7707 but is mounted backward for Tank 7708 making it inconsistent and potentially may lead to misidentification of alarm conditions.

CODE REFERENCE: UFC 3-460-01 Table 8-1 (l)

RECOMMENDATION: Replace the missing label and consider aligning the level alarm uniformly on the same panel.

ee. Pilot Tubing Without Supports OBSERVATION: The ½ stainless steel (SS) tubing from the HLV to HLV Float Pilot has a section of unsupported tubing near the tank foundation (adjacent to the shut-off valve).

CODE REFERENCE: API 570 Section 3.1.11 contact point (The locations at which a pipe or component rests on or against a support or other object which may increase its susceptibility to external corrosion, fretting, wear, or deformation).

RECOMMENDATION: Install supports.

ff. Set Screw on Cla Val OBSERVATION: The jam nut on the 55F Pressure Relief Control set screw is not locked in potion

CODE REFERENCE: Manufacturer’s instruction and UFC 3-460-01 (bb)

RECOMMENDATION: Calibrate, test, and install a lead seal on all pressure relief devices on the CLA Val.

gg. Product Piping Label Marking OBSERVATION: The tank piping within the dike does not all have yellow bands/product symbols and directional arrows.

CODE REFERENCE: Identify all pipelines and tanks as to product service by color coding, banding, product names, NATO designation, and directions of flow in accordance with MIL-STD-161. AW

78‐24‐27 Drawing D.13 Detail (3). (Refer to MIL-STD-161G for correct fuel type).

RECOMMENDATION: Install yellow bands/product symbols.

hh. Conduit Seal-Off (PST Pump) OBSERVATION: There is no seal-off provided for the Product Saver Tank (PST) pump conduit at the secondary containment exit area. Seal-off is required where the NFPA electrical classification of the area changes, such as where it leaves the secondary containment

CODE REFERENCE: Article 501 of NFPA-70 lists the requirements for Class I hazardous locations’ sealing requirements. The purpose of the seal is to “minimize the passage of gases and vapors and prevent the passage of flames from one portion of the electrical installation to another through the conduit.”

RECOMMENDATION: Install seal-off in locations where boundaries change. A conduit seal is required in each conduit run leaving a Class I, Division 2 location.

ii. Circumferential Stairway Bottom Landing OBSERVATION: The tank foundation presents an 18 inch step up before getting to the circumferential stairway. This is not per OSHA requirements for consistent dimensions of stairways.

CODE REFERENCE: OSHA 1910.25, "Stairs have uniform riser heights and tread depths between landings.”

RECOMMENDATION: Future plans should consider adding a short access stairway to meet current OSHA and industry requirements. All access staircases in the tank area should have consistent dimensions.

jj. Explosion Proof Conduit Sealing Compound

OBSERVATION: The explosion proof conduit sealing fitting is missing the sealing compounds on multiple point liquid level control system. This will not meet the Class 1, Division 2 rating requirements for hazardous locations

CODE REFERENCE: All wiring and fittings in a Class 1 location that is a bulk plant or terminal must comply with the applicable provisions of NEC Article 501 or Article 505 [515.7].

RECOMMENDATION: Install sealing compound IAW with the manufacturer’s standards and the

National Electrical Code (NEC) in Article 501, Section 501-5.

kk. Secondary Containment Cathodic Protection Soil Access Plugs OBSERVATION: Several of the Cathodic Protection (CP) soil access plugs were loosely fitted on the basin floor ports. The area was filed with water and monitored. Loss in water level was noted on two of the plugs (south side and west side). This can compromise the integrity of the secondary containment basin.

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: Ensure all CP soil access plugs are secured and liquid tight after use. Ensure sealing plug material used is compatible or resistance to hydrocarbon.

ll. Multiple Point Liquid Level Control Panel (Broken bulbs)

OBSERVATION: The bulbs on the multiple point liquid level control system used for independent level alarm panel did not all light up when tested. Lights with burned out bulbs are circled below. The audible horn and alarm light above the panel were in working condition.

CODE REFERENCE: UFC 3-460-01 Table 8-1 (l)

RECOMMENDATION: Repair/replace bulbs and ensure the alarm panel has both audible and visual indicators in working operation.

mm. VITO Water probe and ENRAF ATG OBSERVATION: The ENRAF ATG float and VITO water probe share a common roof nozzle. Possible entanglement could damage the system and provide inaccurate measurements. The Vito water probe should be in a separate well that is near the sump (Note: tank is furnished with addition stilling well).

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

RECOMMENDATION: Install the VITO water probe in a separate stilling well.

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

Long-term Repairs that directly relate to repair/upgrade of an asset to bring it up to the current standard from the standard at time of construction. Long-term Repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. The Contrast On The Roof Mounted ENRAF Display

OBSERVATION: The contrast on the roof mounted ENFRAF is too dark to properly read the tank level.

CODE REFERENCE: Part of regular maintenance

RECOMMENDATION: Adjust the contrast on the ENRAF ATG.

b. Galvanic Corrosion OBSERVATION: The ½ stainless steel (SS) tubing, the galvanized unistrut, and cast iron basin drain cover are periodically submerged underwater when there is precipitation. This is promoting galvanic series corrosion due to different potential of each material. Corrosion was noted on the galvanized unistrut and carbon steel drain cover.

CODE REFERENCE: Part of regular maintenance.

Recommendation: Monitor the area and frequently drain the secondary containment.

c. Total Coating Failure On Receipt Piping OBSERVATION: There is near total coating failure on the receipt pipping within the dike.

CODE REFERENCE: Part of regular maintenance and UFC 3-460-03 Section 6-10 and UFGS Specification

33 52 43.13 Aviation Fuel Piping or 09 97 13.27 Exterior Coating of Steel Structures

RECOMMENDATION: Mechanically clean and recoat areas of coating failure on the piping.

d. Total Coating Failure/Separation On Receipt DBB valve OBSERVATION: There is near total coating failure on the receipt pipping DBB valve with poorly adhered coating.

CODE REFERENCE: Part of regular maintenance and UFC 3-460-03 Section 6-10 and UFGS Specification

33 52 43.13 Aviation Fuel Piping or 09 97 13.27 Exterior Coating of Steel Structures

RECOMMENDATION: Mechanically clean and recoat the areas of coating failure on the DBB valve.

e. Bend Radius on Flex Conduit

OBSERVATION: The bend radius on the flex conduit on the Product Saver Tank is over the manufacturer’s recommended radius. The minimum recommended bend radius for a ¾” hub size is twelve (12) inches. The conduit is currently bent to a six (6) inch radius. Over bending the flex conduit could damage the brass inner core and insulating wire duct which may allow an ignitable mixture to enter in the conduit system

CODE REFERENCE: Manufacturer’s instruction and good engineering practice.

RECOMMENDATION: Monitor the flex conduit and replace as needed.

f. Coating Failure and Corrosion on Abandoned Pipes OBSERVATION: There are four abandoned pipes that penetrate the secondary containment basin with moderate coating failure and corrosion.

CODE REFERENCE: Part of regular maintenance and to maintain secondary containment integrity

RECOMMENDATION: Maintain all basin-to-pipe penetrations as well as pipe integrity to prevent any future breach within the secondary containment basin.

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 BOTTOM SERVICE LIFE EVALUATION (N/A – Not Performed)

A.2 SHELL SERVICE LIFE EVALUATION (N/A – Not Performed)

A.3 SHELL SETTLEMENT EVALUATION (N/A – Not Performed)

A.4 ULTRASONIC UT DATA (N/A – Not Performed)

A.5 CONTAINMENT LAYOUT DRAWING

A.6 BOTTOM LAYOUT DRAWING (N/A – Not Performed)

A.7 SHELL LAYOUT DRAWING

A.8 ROOF LAYOUT DRAWING

A.9 OSHA ACCESS STRUCTURE REPORT

Remarks/Legend:

Owner/Operator:

Inspection Firm:

Date: Revision Number: Revision Date:

Drawing Title: Tank Description: Drawing Number:

InterSpec, LLC.

11/20/2019 N/A N/A

Tank 7706 S-1Shell Layout [1 of 2]

A - 30" Manway B - 3" Low Suction C - 6" Issue D - 2" Water Draw/ Pressed Steel Tank Return E - 3/4" Brass Valve F - 4" Vapor Recovery (Skillet) G - 6" Receipt H - 1" High Level Alarm Tank Connection I - 1" High Level Alarm Tank Connection J - 1" Low Level Alarm Tank Connection K - 1" Low Level Alarm Tank Connection L - 24" Clean Out

Seam #1 is the first shell seam left of the manway on the first…