Attachment J3 - Irwin-Fac 7708JT (Tank 7708JT)-FINAL-2020.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service External Inspection Report

Fort Irwin; Fort Irwin, California Facility Number 7708

Tank Number 7708

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 7708)

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 7708 (Facility 7708) 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 33 Linear Feet (LF) of unsealed cracks.

b. The concrete secondary containment berm has approximately 116 LF of minor to moderate cracks on the interior section of the wall.

c. The concrete secondary containment berm walkway has approximately 40 LF of minor to moderate cracks on the top section of berm.

d. The concrete secondary containment basin has approximately 1.5 LF of minor deteriorated sealant (four locations).

e. There is one area of broken concrete/spalling on northwest side of the dike.

f. The concrete secondary containment berm walkway has approximately 1 LF of minor deteriorated sealant on the top section of berm.

g. The foundation-to-bottom projection (chime) interface is sealed. There are intermittent areas of failed sealant at the interface (approximately 6 LF = entire perimeter).

h. 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- 15/16 inches.

i. The 4” Vapor recovery line from tank 7706 is routed inside the dike for tank 7708. The line is equipped with a 2” brass valve. 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.

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

k. The tank markings have faded/peeled.

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

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

n. The raised foundation is repaired with resurfacing/coating material. Isolated areas of failure in the coating with exposed cracks were noted at two locations. 1.5 LF near the cleanout and 3 LF Southside of the foundation where pilot toping ascends tank shell.

o. 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 reading = 02’ 4 - 6/16” and

ATG reading = 25 1 - 8/16”. The MTG tapes is spun out and currently stuck between the Internal

Floating Roof (IFR) wiper seal and tank shell. The Display is also faded on the MTG.

p. The existing mechanical tape gauge Varec (Model 2500) is not per manufacture specification. The

Tape is fastened to the top of the internal floating roof (IFR). Due to this configuration, a "bump check" was not performed on the mechanical gauge head. The tape gauge should not be attached to the floating roof, per the manufacturer.

q. 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.

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

s. The fixed roof center vent is equipped with a course mesh screen that is larger than what is listed in

API std. 650. Axiom opening per API Std. 650 is ¾”.

t. There is excessive opening on one side of the center vent.

u. Tank is equipped IFR. Inspection from hatch indicates there areas some visible gaps between the perimeter seal and tank shell with fuel visible at some areas.

v. 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.

w. 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.

x. The tank foundation presents a 15 inch step up before getting to the circumferential stairway. This is not per OSHA requirements for consistent dimensions of Stairway.

y. The ½ stainless steel (SS) tubing from tank 7706 is routed through dike for this tank. The tubing does not have adequate support and is resting on concrete basin.

z. 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.

aa. Secondary containment piping are supported on unistrut without the use of Teflon spacers

(Quantity = 30).

bb. There is no seal-off provided for the high level transmitter and Product Saver Tank (PST) pump conduits 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.

cc. The NPS 6 issue 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.

dd. The issue piping is supported on unistrut with a Teflon material between pipe and the unistrut.

Teflon on the North corner of piping was dislodge from support. (Quantity = 1).

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

ff. The ENRAF ATG float and VITO water probe share a common stilling well. Possible Entanglement could damage 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).

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 roof mounted ENFRAF 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. 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.

c. The three conduits to the Enraf ATG and Water probe are not supported on the roof. One of the conduits is resting on the roof handrail toeboard.

d. Tank is not equipped with a shell manhole located above the internal floating pan’s high position.

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 + 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: 15 June 2006 API In-Service (External) Inspection Date: 2 February 2015 Alteration/Repairs Completed: 2012

New NPS 8 MTG, NPS 8 ATG and NPS 6 water probe poles, NPS 2 Water draw 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): 15 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 7708

Tank Number 7708

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 24 Feet – 8Inches

Shell Height 36 Feet

Product Height 32.5 Feet

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

Foundation Concrete Ringwall

Construction

Bottom Lap‐Welded (Cone‐Down)***

Shell Butt‐Welded (Cylindrical)

Floating Roof Full Contact Honeycomb

Fixed Roof Lap Welded (Cone-Up)

Material

Bottom Carbon Steel (unknown specification)

Shell Carbon Steel (unknown specification)

Floating Roof Aluminum (unknown specification)

Fixed Roof Carbon Steel (unknown specification)

Cathodic Protection Impressed Current

Interior Coating System N/A

Exterior Coating System Epoxy with a polyurethane (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 29.33 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: 3.193 Feet Low‐Low Level Alarm: 1.599 Feet High‐Level Alarm: 25.714 Feet High‐High Level Alarm: 27.854 Feet High‐Level Control Shutoff: 29.33 Feet

Type of Internal Floating Roof

Full Contact Honeycomb with Primary and Secondary polyurethane wipers

***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 performed for Tank 7708 (Facility 7708).

2. Site Information

On November 20, 2019 InterSpec, LLC under contract to Argus Consulting Inc. performed a visual external inspection, in-service, of Tank 7708 (Facility 7708) 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 7708 (Facility 7708) is used as an aboveground fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 7708 (Facility 7708) is a nominal 2,380 BBL (100,000 Gallon), 24.67‐foot diameter by 36‐foot tall, Jet 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 were repairs/alterations performed on this tank, and they included installation of a new NPS 8 and NPS 4 aluminum poles and miscellaneous repairs that was completed in 2012 by CAPE.

2. Tank Foundation

The tank sits on a concrete ringwall foundation that is elevated approximately fifteen (15) 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. The bottom plate extension (chime) is sealed and is in satisfactory condition. The foundation is repaired with resurfacing/coating material. Isolated areas of failure in the coating with exposed cracks were noted at two locations. (1.5 LF near the cleanout and 3 LF southside of the foundation where the pilot toping ascends tank shell).

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 four (4) 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

The tank is equipped with a full surface contact aluminum honeycomb design that is fitted with primary and secondary wiper perimeter seals. The IFR was at approximately 25’ above the tank bottom at the time of the inspection and is supplied with five (5) floating roof legs. Inspection from the hatch indicates there areas some visible gaps between the perimeter seal and tank shell with fuel visible at some areas.

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 Varec (Model 2500). The overall general conditions of the tank gauging systems are unsatisfactory. At the time of the inspection, the MTG was indicating a different tank product level compared to the ATG. MTG reading = 02’ 4 - 6/16” and ATG reading = 25 1 - 8/16”. The MTG tape is spun out and currently stuck between the

Internal Floating Roof (IFR) wiper seal and tank shell. The display is faded on the MTG. The

MTG is not per manufacturer specification. The tape is fastened to the top of the internal floating roof (IFR).

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 the same float switch 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 an 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 four grounding cables connected to the tank via grounding lugs with one rectifier lead structural wire attached to the bottom projection. 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 little to minor coating failure on the tank shell with minor coating failure on appurtenances and roof plates.

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). 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 60 feet x 60 feet (basin footprint), with a sloped berm and a vertical height of 51.44 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 33 linear feet of cracks in the secondary containment basin were identified. An additional 116 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

40 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 walkway has approximately 1 linear foot of minor deteriorated sealant on the top section of berm. Approximately 1.5 LF sealant failures were identified on the secondary containment concrete basin. One area of spalling measuring 24-inches by 8-inches was identified on the berm walkway (northwest 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 149,160 gallons of containment capacity (149%). 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 Tanks 7706 and 7708. The rectifier was installed in 2010 and is located on the north-west 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 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 asset. 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 33 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 116 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 40 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 Basin Sealant Deterioration

OBSERVATION: The concrete secondary containment basin has approximately 1.5 LF of deteriorated sealant in the basin.

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

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

e. Spalling On Top Of Berm Walkway

OBSERVATION: There is one area of broken concrete/spalling on northwest side of the dike.

RECOMMENDATION: Repair the spalling on the secondary containment berm (24” x 8” area).

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

OBSERVATION: The concrete secondary containment berm walkway has approximately 1 LF of minor deteriorated sealant on the top section of berm.

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

g. Tank Bottom Extension (Chime) Sealant Failure

OBSERVATION: The foundation-to-bottom projection (chime) interface is sealed. There are intermittent areas of failed sealant at the interface (approximately 6 LF = entire perimeter).

CODE REFERENCE: Seal should be maintained in good working order to prevent corrosion of the underside of the tank bottom (UFC 3-460-03 Section 8-4.1 B).

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

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

h. 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- 15/16 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.

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

OBSERVATION: The 4” Vapor recovery line from Tank 7706 is routed inside the dike for Tank 7708.

The line is equipped with a 2” brass valve. 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).

j. 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.

k. 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 markings.

l. 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).

m. 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.

n. Foundation Cracks

OBSERVATION: The raised foundation is repaired with resurfacing/coating material. Isolated areas of failure in the coating with exposed cracks were noted at two locations. 1.5 LF near the cleanout and 3

LF southside of the foundation where the pilot toping ascends tank shell.

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. Resurface or repair using a similar concrete coating system to prevent water intrusion in to the rebar.

o. Mechanical Tape Gauge Out of Calibration/ Tape is Spun Out of the MTG Head

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. MTG reading

= 02’ 4 - 6/16” and ATG reading = 25 1 - 8/16”. The MTG tape is spun out and currently stuck between the Internal Floating Roof (IFR) wiper seal and tank shell. The display is also faded on the

MTG.

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

RECOMMENDATION: Repair the MTG and calibrate the mechanical tape gauge.

p. Mechanical Tape Gauge Attached to the IFR

OBSERVATION: The existing mechanical tape gauge Varec (Model 2500) is not per manufacturer specification. The tape is fastened to the top of the internal floating roof (IFR). Due to this configuration, a "bump check" was not performed on the mechanical gauge head. The tape gauge should not be attached to the floating roof, per the manufacturer.

CODE REFERENCE: General maintenance/ manufacturer’s instruction/UFC 3-460-01 Table 8-1 (q)

RECOMMENDATION: Calibrate the mechanical tape gauge after placing the tank in service. Do not turn the operation checker knob on systems that have no float and that are directly connected to a floating roof. Install a sign that reads, “DO NOT OPERATE CHECKER KNOB.” This signage can be displayed until the tape gauge is reinstalled in accordance with the manufacturer's instructions. The mechanical tape gauge can be retrofitted by attaching the tape to a six-pound weight (preferably aluminum), which can be placed on top of the floating roof.

q. 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).

r. 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.

s. Center Vent Course Mesh Screen Size OBSERVATION: The fixed roof center vent is equipped with a course mesh screen that is larger than what is listed in API Std. 650. The maximum opening per API Std. 650 is ¾”.

CODE REFERENCE: API 650 5.8.5.5, “All free vents shall be provided with corrosion-resistant coarse mesh bird screens of a maximum opening size of (19 mm [3/4 in.] nominal opening).”

RECOMMENDATION: Replace the mesh screen with a one that has a maximum size of ¾” opening (do not use insect screen).

t. Center Vent Mesh Screen (Damage) OBSERVATION: There is an excessive opening on one side of the center vent.

CODE REFERENCE: API 650 5.8.5.5, “All free vents shall be provided with corrosion-resistant coarse mesh bird screens of a maximum opening size of (19 mm [3/4 in.] nominal opening).”

RECOMMENDATION: Replace the mesh screen with a one that has a maximum size of ¾” opening (do not use insect screen).

u. Internal Floating Roof (IFR) Wiper Seal OBSERVATION: The tank is equipped with an IFR. Inspection the from hatch indicates areas with some visible gaps between the perimeter seal and tank shell with fuel visible at some areas.

CODE REFERENCE: UFC 3-460-01 2-14.2.2 “Tanks containing Class I flammable fuels or mission-critical

Class II combustible fuels, such as JP-8, must be equipped with a full contact, aluminum honeycomb floating pan. Other Class II fuels require a full contact, aluminum honeycomb floating pan if the tank does not comply with the spacing and diking requirements of this UFC.”

RECOMMENDATION: Perform an additional IFR wiper seal inspection to determine the condition of the seal (entry on top of the IFR with supplied air may be required to get a complete inspection of the IFR seal without taking the tank out-of-service).

v. 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 a sealing compound IAW with the manufacturer’s standards and the National Electrical Code (NEC) in Article 501, Section 501-5.

w. 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 the bulbs and ensure the alarm panel has both audible and visual indicators in working operation.

x. Circumferential Stairway Bottom Landing OBSERVATION: The tank foundation presents a 15 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.

y. Pilot Tubing Without Supports OBSERVATION: The ½ stainless steel (SS) tubing from Tank 7706 is routed through the dike for this tank. The tubing does not have adequate support and is resting on concrete basin.

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.

z. 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.

aa. Pipe Support Teflon Spacers OBSERVATION: Secondary containment piping are supported on unistrut without the use of Teflon spacers (Quantity = 30).

CODE REFERENCE: AW 78-24-27 drawing on CD.11 (PS-1 and PS-2) indicated piping with Teflon coated U-bolts or Teflon spacer to prevent abrasion damage to coating and piping

RECOMMENDATION: Install Teflon spacers.

bb. Conduit Seal-Off (PST Pump and HLA/HHLA Transmitter) OBSERVATION: There is no seal-off provided for the high level transmitter and Product Saver Tank

(PST) pump conduits 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

cc. NPS 6 Issue Nozzle Weld Spacing OBSERVATION: The NPS 6 issue 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 (Figure 5.6 - Minimum Weld Requirements for Openings in Shells).

RECOMMENDATION: Modify the reinforcement pad of the nozzle 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.

dd. Pipe Support Teflon Spacers (Issue Pipe) OBSERVATION: The issue piping is supported on unistrut with a Teflon material between pipe and the unistrut. Teflon on the North corner of piping was dislodge from support. (Quantity = 1).

CODE REFERENCE: AW 78-24-27 drawing on CD.11 (PS-1 and PS-2) indicated piping with Teflon coated U-bolts or Teflon spacer to prevent abrasion damage to coating and piping

RECOMMENDATION: Install Teflon spacers.

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

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.

ff. VITO Water probe and Enraf ATG Stilling Well OBSERVATION: The ENRAF ATG float and VITO water probe share a common stilling well. Possible

Entanglement could damage 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 (v) and (w). See 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 unistsrut and Carbon steel drain cover.

CODE REFERENCE: Part of regular maintenance.

RECOMMENDATION: Monitor area and frequently drain the secondary containment.

c. Conduits Not supported (Fixed Roof) OBSERVATION: The three conduits to the Enraf ATG and Water probe are not supported on the roof.

One of the conduits is resting on the roof handrail toeboard.

CODE REFERENCE: Part of regular maintenance/design requirements

RECOMMENDATION: Provide support for the conduit.

d. IFR Access Shell Manhole OBSERVATION: The three conduits to the Enraf ATG and Water probe are not supported on the roof.

One of the conduits is resting on the roof handrail toeboard.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (c) “A shell manhole located above the internal floating pan’s high position to aid in venting the tank during cleaning and to provide access to the floating pan’s elastomeric wiper seals as required by DoD Standard AW 078-24-27.”

RECOMMENDATION: Install manhole above the IFR pan’s high position per AW 078-24-27 (See UFC 3-

460-01 Chapter 12)

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:

US Army - Fort Irwin; Barstow, CA

InterSpec, LLC.

11/20/2019 N/A N/A

Tank 7708 S-1Shell Layout [1 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.

A - 32" Manhole B - 3" Low Suction C - 6" Issue Nozzle D - 2" Product Saver Tank Return E - 2" Product Saver Tank Suction (Water Draw) F - 1" Low Level Sensor/Low-Low Level Sensor

Connection G - 1" Low Level Sensor/Low-Low Level Sensor

Connection H - 6" Receipt I - 1" High Level Sensor/High-High Level

Sensor/HLV Float J - 1" High Level Sensor/High-High Level

Sensor/HLV Float K - Cleanout

A

B C

D E

F

G H

Ground Anchor Bolt

Mechanical Tape Guage

Overflow Vent

1-1 1-2

2-2 2-3

3-1 3-2

4-1 4-2

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 7708 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.

A - 32" Manhole B - 3" Low Suction C - 6" Issue Nozzle D - 2" Product Saver Tank Return E - 2" Product Saver Tank Suction (Water Draw) F - 1" Low Level Sensor/Low-Low Level Sensor

Connection G - 1" Low Level Sensor/Low-Low Level Sensor

Connection H - 6" Receipt I - 1" High Level Sensor/High-High Level

Sensor/HLV Float J - 1" High Level Sensor/High-High Level

Sensor/HLV Float K - Cleanout

I

J

K

6" x 8" Repad

4-3 4-4

3-3 3-4

2-3 2-4

1-3 1-4

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 7708 R-1Roof Layout [1 of 1]

The measured tank diameter is 25 feet.

The roof consists of 8 plates.

A - 2" Anti-Rotation Device B - 30" Inspection Hatch (Vavec Fig 220) C - 10" Nozzle With 8" Sample/Gauge Hatch D - 10" Nozzle With 8" Automatic Tank Gauge

Well E - 2" Anti-Rotation Device F - Internal Floating Roof Grounding Cable G - 72" x 24" Internal Floating Roof Panel

Access Hatch H - 36" x 48" Internal Floating Roof Access Hatch I - 10" Nozzle with 6" Well J - 30" Center Vent K - 2" Internal Floating Roof Grounding Cable L - 30" Inspection Hatch (Varec Fig 220)

M - 2" ARD

N - 2" Mechanical Tank Gauge Tape

O - 2" ARD

P - 9" x 48" Circulation Vent/ Inspection Hatch Q - 9" x 48" Circulation Vent/ Inspection Hatch

1 2

5 6

7 8

A

B C D

E F

GH

I

J

K L

M

N

O

P

Q

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 7708 C-1Containment Layout [1 of 1]

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

N

- Cracks

- Sealant Failure

- 6" Receipt Piping (7706)

- 6" Receipt Piping (7708)

- 6" Issue Piping (7708)

- 4" Vapor Recovery Line (7706)

- Pipe Support

- Valve

- Cathodic Protection Soil Access

- Abandoned Pipe

Tank 7708

24" x 8" Spalling

Drain Valve

H = 52 1/2H = 51 1/4

H = 51 3/4H = 50 1/4

Product Saver Tank

OSHA ACCESS STRUCTURE REPORT

OSHA Stairway Data

OSHA Required Range

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

Circumferential Stairway Handrail Height 30 34 32

Platform Railing Height 42 - 42

Platform Midrail Height 21 - 22

Circumferential Stairway Width 28 - 34

Platform Toeboard Height 4 - 4

Platform Landing Width 30 - 30

Platform Toeboard gap NA 1/4 1/4

Roof Perimeter Railing Height 42 - 42

Roof Perimeter Midrail Height 21 - 22

Roof Perimeter Toeboard Height 4 - 4

Roof…