Attachment J2 - Irwin-Fac 7707 (Tank 7707)-FINAL-2020.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service External Inspection Report

Fort Irwin; Fort Irwin, California Facility Number 7707

Tank Number 7707

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 7707)

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 7707 (Facility 7707) 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 assessing 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 9 Linear Feet (LF) of unsealed cracks).

b. The concrete secondary containment berm has approximately 38 LF of minor to moderate cracks on the interior section of the wall.

c. The concrete secondary containment berm walkway has approximately 50 LF of minor to moderate cracks on the top section of berm.

d. The concrete secondary containment berm walkway has approximately 2 LF of minor deteriorated sealant on the top section of berm

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

f. The manhole reinforcement plate-to-shell vertical 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 1- 11/16 inches.

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

h. The NPS 6 issue piping is equipped with flange isolation kit. Deteriorated gasket around edges was noted as well as damaged bolt sleeves.

i. The gasket on NPS 6 issue has weathered and shows some edge damage.

j. The NPS 8 receipt piping is not equipped with flange isolation kit.

k. The ¾” water draw 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.

l. The receipt TRV piping is equipped with a glass sight flow indicator.

m. The issue line is not equipped with TRV and bypass piping. Receipt TRV is not per current design standard (stainless steel piping)

n. The tank is not equipped with a confined space marking.

o. The tank markings have faded/peeled.

p. 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.

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

r. The secondary containment is not equipped with access stairway. The Secondary Containment consists of a sloped dike berm.

s. Tank is not equipped with product saver tank/water draw-off system per AW 78-24-27.

t. The raised foundation has circumferential crack around the entire circumference. Crack starts at approximately ten inches above the basin and loops down to about one inches above the basin.

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

u. The tank is equipped with a Mechanical Tape Gauge (MTG). At the time of the inspection the MTG was indicating a different tank product level compared to the ATG. MTG is out of calibration. MTG reading = 16’ 7-1/16” and ATG reading = 10’ 5-9/16”

v. 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.

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

x. Tank is equipped with a two roof mounted Pressure Vacuum (P/V) Vents. P/V Vents are missing screen on the pressure side of the Varec Fig 2010 device. There is potential for birds to build nest on top of the P/V vent pallet which will rendering it inoperable.

y. 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 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 potential may lead to misidentification of alarm conditions.

z. The tank foundation presents a 20 inch step up before getting to the circumferential stairway. This is not per OSHA requirements for consistent dimensions of Stairway.

aa. There are 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.

bb. 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

cc. 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. Lose 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.

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

ee. The stairway has inadequate clearance between the handrail and the HLV Float chamber/tubing.

The existing clearance between HLV chamber and handrail is 19 inches. 29 CFR 1910.25 requires a minimum width of 22 inches.

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

a. There are minor coating failure and corrosion on the tank, appurtenances , staircase and flanged fittings.

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

c. The CP and leak detection ports penetrate through the ring via sleeves. The spacing around the sleeve is not sealed (most have foam spacer and some have deteriorated seal). Water intrusion to the underside of the tank bottom is likely during high water/precipitation conditions inside dike.

d. The LLA/LLLA chamber piping are constructed with threaded piping and fittings. Staining was noted at the threaded joints.

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

f. There are several adhesive materials left behind form old placards/stickers on the tank shell at the base of the circumferential stairways. Coating failure is noted at these areas.

g. Tank is not is equipped with a full perimeter railing system that encloses all roof appurtenances.

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: 18 June 2006 API In-Service (External) Inspection Date: 2 February 2015 Alteration/Repairs Completed: 2008 New 5/16"(A36) Bottom and Nozzle Modification

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): 18 June 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 7707

Tank Number 7707

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 Jet Fuel (F-24)

Tank Serial Number None

Tank Diameter 45 Feet

Shell Height 30 Feet

Product Height 29 Feet

Tank Capacity 7,143 BBL (300,000 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 (ASTM A36)

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 Thin Film Epoxy (Tan)

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

Overfill Protection Hydraulically Operated High Level Shut-Off Valve with Float (Set at 24.40 Feet)

Piping Receipt 6" Carbon Steel

Issue**** 6” Carbon Steel

Low Suction 3" Carbon Steel

Water Draw-Off 3/4" Carbon Steel

Level Alarms (ATG Set Points)

Low‐Level Alarm: 4.495 Feet Low‐Low Level Alarm: 1.500 Feet High‐Level Alarm: 23.615 Feet High‐High Level Alarm: 24.896 Feet High‐Level Control Shutoff: 24.396 Feet

Type of Internal Floating Roof

None

***Per previous internal inspection Report

**** Shell Nozzle/DBB/HLV are NPS 8

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, performed for Tank 7707 (Facility 7707).

2. Site Information

On November 20, 2019 InterSpec, LLC under contract to Argus Consulting Inc. performed a visual external inspection, in-service, of Tank 7707 (Facility 7707) 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 7707 (Facility 7707) is used as an aboveground fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 7707 (Facility 7707) is a nominal 7,143 BBL (300,000 Gallon), 45‐foot diameter by 30‐foot tall, F‐24 (Jet Fuel), aboveground vertical storage tank. The tank was fabricated by Pitt-Des Moines, Inc. and erected by Hydrostorage, Inc. in 1986 to unspecified standard. There was repairs/alterations performed on this tank, and they include installation of a new 5/16"(A36) bottom and nozzle modification that was completed in 2008 by CAPE.

2. Tank Foundation

The tank sits on a concrete ringwall foundation that is elevated approximately seventeen (17) inches above the secondary containment floor. The foundation is equipped with a leak detection (tell‐tale) system that extends through the ringwall and presumably extends to the center of the tank. 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 bottom plate extension (chime) is sealed and is in satisfactory condition. The foundation has circumferential cracking around the entire circumference. Cracking starts at approximately ten 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 sized as 30" and 36". The tank is equipped with shell mounted 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 an 8-inch aluminum stilling well using a 10-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 Shand & Jurs (Model 92021-31050100). 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 = 16’ 7-1/16” and ATG reading = 10’ 5-9/16”. The “bump check” function of the MTG was tested and is in working condition.

d. Level Alarms

The high-high and high level sensor is mounted on the shell and is 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 a low level sensor. The High-High Level

Sensor (HHLS), High Level Sensor (HLS), 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 high liquid level shut-off valve (HLV) that is actuated by a shell mounted HLV float pilot. The tank is not equipped with an independent low‐low level alarm system as required by military criteria. 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 exceptions – 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. 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 with an unknown completion date. There is moderate coating failure on the upper southeast side of the tank shell, with minor coating failure on appurtenances and remaining shell plates. There is a total coating failure on the receipt piping. Several areas of standing water were noted on the fixed roof. Surface corrosion was noted at the areas of coating failure.

7. Tank Piping System

The fuel is received through 6-inch carbon steel piping that enlarged to NPS 8 with a CLA Val and DBB valve at the tank. The product is issued through a 6-inch carbon steel piping. Other auxiliary piping for the water draw (NPS 3/4) and low suction (NPS 3) are installed, and both terminated at the tank without additional piping inside the basin. 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 dimension of the secondary containment is 100 feet x 100 feet (basin footprint), with a sloped berm and a vertical height of 52.5". 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 9 linear feet of cracks in the secondary containment basin were identified. An additional 38 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

50 linear feet of minor to moderate cracks on the top section of 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 berm walkway has approximately 2 linear feet of minor deteriorated sealant on the top section of berm. 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 414,000 gallons of containment capacity (138%). 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 impressed current Cathodic Protection (CP) system is installed on this tank which is serving the tank bottom. The rectifier was installed in 2007 and is located on the west side of the tank berm. The CP system is manufactured by Universal Rectifiers, Inc. (Model ASAI with serial # 084446). This unit is a

50 volt 5 ampere air-cooled rectifier unit. The CP system is listed as having a mixed metal oxide anode ribbons configured in six loops beneath the tank bottom. The CP is provided with a VIP x 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 9 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 38 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 50 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 Walk Way Sealant deterioration (Top of Berm)

OBSERVATION: The concrete secondary containment berm walkway has approximately 2 LF of minor deteriorated sealant on the top section of berm.

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

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

e. 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.

f. Manhole Reinforcement Weld Spacing

OBSERVATION: The manhole reinforcement plate-to-shell vertical 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 1- 11/16 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.

g. Nonstandard Fittings (Flange)

OBSERVATION: The 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 minimum thickness given in table 5.8b.

h. Flange Insulating kit Is Damaged (NPS 6 Issue Line, 2nd Flange)

OBSERVATION: The NPS 6 issue piping is equipped with a flange isolation kit. Deteriorated gaskets around edges were noted as well as damaged bolt sleeves.

CODE REFERENCE: API 651 paragraph 7.3.6.1 “Isolation devices consisting of flange assemblies, prefabricated isolating joints, or couplings should be installed where electrical isolation of the system is required to facilitate the application of corrosion control…”

RECOMMENDATION: Test and/or replace isolation kits to facilitated proper function of the CP system.

(The march 27th, 2019 CP report did indicate tank was receiving adequate CP protection).

i. Weathered or Aged Gasket (NPS 6 Issue Line, 3rd Flange)

OBSERVATION: The gasket on NPS 6 issue has weathered and shows some edge damage.

CODE REFERENCE: API RP 574 Section 10.3.5.1, “Sites should have a program to assure that flanges are made up properly. Proper make-up of every flange in a piping system is important for reliability.

Proper make-up includes the use of the proper gasket and fastener material, type and size, proper positioning of the gasket and proper torquing of the fasteners. The assurance program should include procedures for gasket and fastener selection and for fastener torquing.”

RECOMMENDATION: Monitor and replace the gasket at the next maintenance or out-of-service outage.

j. No Flange Insulating (NPS 8 Receipt Flange)

OBSERVATION: The NPS 8 receipt piping is not equipped with a flange isolation kit.

CODE REFERENCE: API 651 paragraph 7.3.6.1 “Isolation devices consisting of flange assemblies, prefabricated isolating joints, or couplings should be installed where electrical isolation of the system is required to facilitate the application of corrosion control….”

RECOMMENDATION: Install an isolating kit on the flange. (The march 27th, 2019 CP report did indicate tank was receiving adequate CP protection).

k. Low Melting Point Material (3/4” Water Draw)

OBSERVATION: The ¾” water draw 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 (future upgrades should consider water draw off system per AW 78-24-27).

l. TRV Piping Glass Sight Flow Indicator (Receipt)

OBSERVATION: The receipt TRV piping is equipped with a glass sight flow indicator.

CODE REFERENCE: AW 78-24-27 and UFC 3-460-01 Section 9.3.5.1.

RECOMMENDATION: Replace the sight flow indicator with a non-glass sight flow indicator in accordance with AW 78-24-27 UFC 3-460-01 Section 9.3.5.1.

m. 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.

n. No Confined Space Markings at Manholes

OBSERVATION: The tank is 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.

o. Faded and Pealing Tank Marking

OBSERVATION: The tank markings have faded/peeled.

CODE REFERENCE: Mark the 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 and “Mark tanks in accordance with NFPA 704.” (UFC 3‐460‐01, Section 2‐17 (b) and (C)).

RECOMMENDATION: Replace the faded tank marking.

p. 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.

q. Personnel Static Electric Discharge

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

27.

CODE REFERENCE: 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.

r. 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.

s. Water Draw-off System (Product Saver Tank)

OBSERVATION: The tank is not equipped with a product saver tank/water draw-off system per AW

78-24-27.

CODE REFERENCE: UFC 3-460-01 Section 8-3.14.1” Provide pumps, piping, valves, and tanks to collect and store usable aviation turbine fuel which would otherwise become waste from operational or maintenance activities. Consider a product recovery system for other products.“

RECOMMENDATION: Future upgrades should consider a water draw off system per AW 78-24-27).

t. Foundation Cracks

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

Cracking starts at approximately ten inches above the basin and loops down to about one inches above the basin. 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.

u. Mechanical Tape Gauge Out of Calibration

OBSERVATION: The tank is equipped with a Mechanical Tape Gauge (MTG). At the time of the inspection, the MTG was indicating a different tank product level compared to the ATG. The MTG is out of calibration. MTG reading = 16’ 7-1/16” and ATG reading = 10’ 5-9/16”.

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

RECOMMENDATION: Calibrate the mechanical tape gauge.

v. 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).

w. 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.

x. Pressure Vacuum (P/V) Vents Missing Screens OBSERVATION: The tank is equipped with two roof mounted Pressure Vacuum (P/V) Vents. P/V Vents are missing screen on the pressure side of the Varec Fig 2010 device. There is potential for birds to build a nest on top of the P/V vent pallet which will render it inoperable.

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 P/V Vents or install new P/V vents.

y. 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. If the alarm is not present on the given tank, consider installing a sign indicating “None.”

z. Circumferential Stairway Bottom Landing OBSERVATION: The tank foundation presents a 20 inch step up before getting to the circumferential stairway. This is not per OSHA requirements for consistent dimensions of stairways.

CODE REFERENCE: OSHA 1910.24 (f) “……Rise height and tread width shall be uniform throughout any flight of stairs including any foundation structure used as one or more treads of the stairs….”

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.

aa. 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.

bb. Explosion Proof Conduit Sealing Compound

OBSERVATION: The explosion proof conduit sealing fitting is missing the sealing compounds on the 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.

cc. 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.

dd. Multiple Point Liquid Level Control Panel (Broken Bulbs)

OBSERVATION: The bulbs on the multiple point liquid level control system used for the 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 the bulbs and ensure the alarm panel has both audible and visual indicators in working operation.

ee. Stairway to Appurtenance Spacing

OBSERVATION: The stairway has inadequate clearance between the handrail and the HLV Float chamber/tubing. The existing clearance between HLV chamber and handrail is 19 inches. 29 CFR

1910.25 requires a minimum width of 22 inches

CODE REFERENCE: OSHA 29 CFR 1910.25

RECOMMENDATION: Reconfigure the high level alarm chamber and bracket or expand the intermediate platform to allow for sufficient spacing to meet OSHA 29 CFR 1910.25.

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. Coating Failure and Corrosion on Appurtenances and Flanges

OBSERVATION: There are minor coating failure and corrosion on the tank, appurtenances , staircase and flanged fittings.

CODE REFERENCE: UFC 3-460-03 Section 8-3.1 Section 6-10 and UFGS 09 97.13.27 (Exterior Coating of

Steel Structures).

RECOMMENDATION: Mechanically clean and recoat areas of coating failure on the tank appurtenances and flanges. Repairs should be accomplished using an epoxy based coating system or equivalent. Do not paint stainless steel, aluminum, or galvanized surfaces (UFC 3-460-03 Section 6-10).

b. The Contrast on the ENRAF Tank Side Indictor (TSI) Display

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

CODE REFERENCE: Part of regular maintenance.

RECOMMENDATION: Adjust the contrast on the TSI to readily read product level at the TSI.

c. Unsealed/Deteriorated Ring wall Penetrations (CP and Leak Detection Ports)

OBSERVATION: The CP and leak detection ports penetrate through the ring via sleeves. The spacing around the sleeve is not sealed (most have foam spacer and some have deteriorated seal). Water intrusion to the underside of the tank bottom is likely during high water/precipitation conditions inside dike.

CODE REFERENCE: Part of regular maintenance.

RECOMMENDATION: Seal wall ringwall penetrations.

d. Threaded Piping and Staining

OBSERVATION: The LLA/LLLA chamber piping is constructed with threaded piping and fittings.

Staining was noted at the threaded joints.

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).

e. Total Coating Failure On Receipt Piping OBSERVATION: There is near total coating failure on 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.

f. Old Placards and Stickers OBSERVATION: There are several adhesive materials left behind form old placards/stickers on the tank shell at the base of the circumferential stairway. Coating failure is noted at these areas.

CODE REFERENCE: Part of regular maintenance and UFC 3-460-03 Section 8-3.1 Section 6-10 and

UFGS 09 97.13.27 (Exterior Coating of Steel Structures).

RECOMMENDATION: Remove left behind adhesive material and apply coating after preparing the surface.

g. Partial Roof Perimeter Railing OBSERVATION: The fixed roof is not equipped with a full perimeter railing system found on military POL facilities. The railing system partially covers half the tank perimeter and cuts across the center of the tank. For this reason all of the roof nozzles are not enclosed by railing system CODE REFERENCE: UFC 3-460-01 Table 8-1(k).

RECOMMENDATION: Install a perimeter railing system per UFC 3-460-01 Table 8-1(k) and guidance from AW 78-24-27 Drawings

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 7707 S-1Shell Layout [1 of 2]

A - 3" Blank B - 6" Issue C - 3/4" Water Draw D - 30" Manway E - 3/4" to 1" Low Level Alarm F - 3/4" to 1" Low Level Alarm G - 1" High Level Alarm H - 1" High Level Alarm I - 1" HLV Float J - 1" HLV Float K - 8" Reciept L - 36" Manway

Seam #1 is the first shell seam left of the manway on the first shell course viewing from the outside.

The number in the upper left corner of each plate identifies the plate by the course and position of the plate in that course.

US Army - Fort Irwin; Barstow, CA

Leak Detection

Ground Cathodic Protection Ground

Cathodic Protection

1-1 1-2 1-3

2-1 2-2 2-3

3-1 3-2

A B C

D E F

G H

I J

Inspection Firm:

Date: Revision Number: Revision Date:

Drawing Title: Tank Description: Drawing Number:

InterSpec, LLC.

11/20/2019 N/A N/A

Tank 7707 S-2Shell Layout [2 of 2]

Seam #1 is the first shell seam left of the manway on the first shell course viewing from the outside.

The number in the upper left corner of each plate identifies the plate by the course and position of the plate in that course.

US Army - Fort Irwin; Barstow, CA

A - 3" Blank B - 6" Issue C - 3/4" Water Draw D - 30" Manway E - 3/4" to 1" Low Level Alarm F - 3/4" to 1" Low Level Alarm G - 1" High Level Alarm H - 1" High Level Alarm I - 1" HLV Float J - 1" HLV Float K - 8" Reciept L - 36" Manway

Mechanical Tape Gauge

3-3

1-4 1-5

2-4 2-5

3-4 3-5

Coating Failure/Corrosion

K

L

Inspection Firm:

Date: Revision Number: Revision Date:

Drawing Title: Tank Description: Drawing Number:

US Army - Fort Irwin; Barstow, CA

InterSpec, LLC.

11/20/2019 N/A N/A

Tank 7707 R-1Roof Layout [1 of 1]

The measured tank diameter is 45 feet.

The roof consists of 36 plates.

A - 30" Inspection Hatch B - 1 1/2" Mechanical Tank Gauge Cable C - 2" Mechanical Tank Gauge Tape D - 1 1/2" Manual Tank Gauge Cable E - 24" Emergency Vent F - 4" Pressure Vaccum Vent G - 4" Water Probe H - 4" Pressure Vaccum I - 6" Manual / Sample Gauge Well J - 8" Manual / Sample Gauge Well K - 10" Automatic Tank Gauge J - 30" Inspection Valve Fig 220 Hatch

- Coating Failure/Corrosion

1 2 3 4 5 6

7 8 9

11 12

13 14 15

16 17 18 22 23 24

A

B C D

E

F G

H

19 20 21I

J K

L

Partial Handrail

Inspection Firm:

Date: Revision Number: Revision Date:

Drawing Title: Tank Description: Drawing Number:

US Army - Fort Irwin; Barstow, CA

InterSpec, LLC.

11/20/2019 N/A N/A

Tank 7707 C-1Containment Layout [1 of 1]

The secondary containment consists of a concrete floor and concrete walls.

- Sealant Failure

- Cracks

- 6" Issue Piping

- 8" Receipt Piping

- Cathodic Protection Soil Access

- Pipe Support

H = 56 1/2 H = 56

H = 55 H = 52 1/2

Tank 7707

N

OSHA ACCESS STRUCTURE REPORT

OSHA Stairway Data

OSHA Required Range

Min (in) Max (in) Actual (in)

Circumferential Stairway Handrail Height 30 34 31.5

Platform Railing Height 42 - 42

Platform Midrail Height 21 - 22

Circumferential Stairway Width 28 - 35

Platform Toeboard Height 4 - 4

Platform Landing Width 30 - 30.5

Platform Toeboard gap NA 1/4 1/4

Roof Perimeter Railing Height 42 - 41.75

Roof Perimeter Midrail Height 21 - 22.25

Roof Perimeter Toeboard Height 4 - 4

Roof Perimeter Toeboard gap NA…