Attachment J3 - MOGAS TANK 901 (NOW M-1) INSPECTION_10 MAY 2016.pdf

TANK FACILITY 901 STI SP001

FORMAL EXTERNAL INSPECTION REPORT

Fort Rucker, Alabama (RCK) A/E Contract No. W9128F-12-D-0006; Delivery Order No. 0007

Submitted to:

U.S. Army Corps of Engineers Omaha District

1616 Capital Avenue; Omaha, NE 68102

10 May 2016

Submitted by:

1011 Boulder Springs Drive, Suite 200; Richmond, Virginia 23225 Phone: 804.592.3900 Fax: 804.592.3901 www.brockenbrough.com

Job No. 15-002.14

CORRECT NUMBERS: 901 (M-1)

SPCC Mandated Shop-Built AST Inspections Fort Rucker, Tank 901

Executive Summary page i

EXECUTIVE SUMMARY

Austin Brockenbrough & Associates, LLP (Brockenbrough) was retained by Omaha District USACE under

Contract No. W9128F-12-D-0006 Delivery Order 0007 to perform SPCC Mandated Shop-Built AST

Inspections. As required by this task, Brockenbrough executed a tank inspection site visit to Fort Rucker near Dale County, Alabama. A formal external inspection per the guidelines of STI SP001 “Standard for the Inspection of Aboveground Storage Tanks” was conducted for Tank Facility No. 901 on June 4th, 2015. This inspection is in compliance with applicable federal, state, and local regulations, as well as the facility’s SPCC Plan.

Tank Facility 901 is an 8'-0" diameter by 25-4" long double wall horizontal tank with a nominal storage capacity of 12,000 gallons of Mogas. The tank was fabricated by Brown Minneapolis Tank in 2004

(estimated by facility personnel). Because this tank has spill control and a continuous release detection method, it is classified as a Category ‘1’ Tank. Details of tank construction and appurtenances are included in Section ‘B’.

There is an Army Petroleum Center (APC) project to replace the ground products system that is in the planning stages, with possible execution in FY 17. Based on the findings of this inspection, we recommend that this project be executed as soon as possible to prevent extensive repairs to this tank.

The 3-inch issue and receipt piping connects to the front head of the tank, penetrating the double wall system. These piping connections invalidate the double wall as a means of secondary containment. A leak in this piping would be contained by the adjacent truck containment area, so there is a marginal means of secondary containment. No repairs are currently recommended for this issue, as it should be addressed by the planned project mentioned above.

With the exception of the above, the tank was found to be fully serviceable, with no mandatory repairs noted that require immediate attention. Several items were observed that are not in compliance with applicable federal, state, and local codes and regulations. The noted deficiencies are included in more detail in Section ‘C’ and should be addressed in a timely manner.

It is recommended that the tank owner’s inspector perform periodic inspections of this tank using the

STI monthly and annual checklists, which are included in Appendix ‘2’ of this report. As this tank is classified as Category ‘1’, STI recommends that the next formal external inspection of this tank be performed by a certified STI SP001 inspector before September 2035. This inspection interval will meet all the applicable requirements for Federal, State, and Local regulations.

Certification Signature:

Bryan Strayer, PE Mechanical Engineer STI Inspector No. AST-990220

Table of Contents page ii

TABLE OF CONTENTS

EXECUTIVE SUMMARY ................................................................................................................................... i

A. General Project Information

1. STI SP001 In-Service Inspections

2. Site Information

3. Previous Inspections

B. Tank Construction and Appurtenances

1. Tank Construction

2. Tank Supports and Foundation

3. Secondary Containment

4. Tank Coating System

5. Tank Appurtenances

a. Venting

b. Gauging

c. Stairs and Platforms

d. Grounding and Bonding

e. Other Appurtenances

6. Tank Piping System

7. Fire Protection Systems:

C. Findings and Recommendations

1. Mandatory Repairs

a. Secondary Containment

2. Recommended Repairs

a. Mechanical Gauging

b. Tank Platforms - Access

c. Tank Platforms – Coating Repair

d. Brush clearing

e. Tank Labeling

3. Other Noted Tank Items

a. Safety Clearances

b. Access Manholes

c. Water Draw-Off Connection

4. Associated Site Upgrades

a. Fire Hydrants

D. Inspection Photographs

E. Tank Configuration Sketch

Appendix ‘1’ – STI Formal External Inspection Checklist

Appendix ‘2’ – STI Monthly and Annual Checklists

General Project Information page 3

A. General Project Information

1. STI SP001 In-Service Inspections

This project will perform in-service inspection of various tanks at facilities throughout the United

States. The basis of this inspection is a formal external inspection recommended in STI SP001

“Standard for the Inspection of Aboveground Storage Tanks”. Additional consideration is given to

Federal, State, and Local regulations as well as applicable Military Criteria and general industry standards. Unless otherwise noted, all inspections will be conducted while the tanks and associated piping systems remain in service.

For Tank 901, an STI SP001 Formal External Inspection was performed.

2. Site Information

On June 4th, 2015 Brockenbrough performed a site visit to Fort Rucker located near Dale County, Alabama to perform inspections of three aboveground storage tanks. Fort Rucker is located mostly in Dale County and encompasses an area of nearly 11 square miles. This facility is the primary

Flight Training Base for Army Aviation, as well as the home to the United States Army Aviation

Center of Excellence (USAACE).

It should be noted that an Army Petroleum Center (APC) sponsored project to replace the ground products system was reportedly in the early planning stages, with a possible execution date of FY

17. The recommendations for repairs for this tank will take this potential replacement project into account. If this replacement project is delayed or cancelled for any reason, the recommendations should be reevaluated on a cost to benefit basis.

3. Previous Inspections

There were no previous formal inspections found to have been performed on Tank 901.

Tank Construction and Appurtenances page 4

B. Tank Construction and Appurtenances

1. Tank Construction

The UL data plate was present and fully readable. The tank is constructed to UL Standard 142 for

"Secondary Containment Aboveground Tank for Flammable Liquids". The tank is double wall steel with seven lap-welded shell courses. Tank heads are flat and lap-welded to the shell. The tank measures 8'-0" diameter by 25-4" long.

2. Tank Supports and Foundation

The tank is supported by steel saddles, each bearing down on the concrete tank pad. The saddles were found to be in good condition.

3. Secondary Containment

The tank is a double wall tank with a continuous interstitial leak monitoring sensor. The tank interstitial space was found to contain 1’-4” of water. No fuel was noted.

4. Tank Coating System

The tank is carbon steel, with an exterior coating that appears to be DoD standard epoxy-polyurethane system. The tank exterior coating was found to be in fair condition, but dirt and algae covered the top of the tank. The interior coating of the tank is unknown.

5. Tank Appurtenances

a. Venting

This tank features a 3-inch Morrison Brothers pressure/vacuum vent, Fig 548. Vent settings were unreadable and the vent could not be safely accessed. Based on the manufacturer’s standard product literature, this vent capacity is in compliance with the recommendations of

STI SP001. The tank has a 10-inch Morrison Brothers emergency vent, Fig 244, with a capacity of 495,000 cfh for both the primary tank and the interstitial space. This vent capacity is in compliance with the recommendations of STI SP001. Both emergency vents were fully operable.

b. Gauging

The tank has a 2-inch nozzle with a Moormann Bros mechanical tape gauge. The tape gauge was unreadable and does not appear to be working. In addition, the tank includes a 4-inch nozzle with a Ronan ATG system mounted through a 24-inch manhole. This level gauging system is combined with a water probe and an interstitial leak sensor.

Tank Construction and Appurtenances page 5

c. Stairs and Platforms

There is an individual ladder and small access platform for this tank. The ladder and platform are coated steel. The platform coating is failing at several locations, with some minor corrosion noted

d. Grounding and Bonding

There is a grounding wire from a lug, welded to tank head, to the tank pad grounding grid.

e. Other Appurtenances

A 4-inch nozzle for sampling and manual gauging is mounted at the access platform. The tank also features a 24-inch manhole, an issue pump mounted on a 4-inch nozzle, a 4-inch temperature gauge, and a 1-inch relief line in a 6-inch nozzle. In addition, two 3-inch piping connections (one for receipt and one for issue) are connected into the front head of the tank

(through the double wall). A 1-inch interstice drain is also located at the bottom of the front of the tank.

6. Tank Piping System

Fuel is received through 3-inch coated carbon steel piping from the associated truck off-loading station. Fuel is issued from the tank to a nearby pump station through 3-inch coated carbon steel piping. This piping supplies the nearby refueler fillstand or a vehicle dispenser.

7. Fire Protection Systems:

There is no fire protection system associated with this storage tank. There was a fire hydrant located within approximately 150 feet of the tank.

Tank Construction and Appurtenances page 6

Table B-1: General Tank Construction Data

Item Description

Owner US Army

Tank Identification Tank Facility 901

Location Fort Rucker, Dale County, Alabama

Manufacturer Brown Minneapolis Tank

Design Standard The tank is constructed to UL Standard 142 for "Secondary Containment Aboveground Tank for Flammable Liquids"

Year Built 2004 (estimated by facility personnel)

Current Product Stored Diesel (DS-2); specific gravity: 0.83 to 0.88, vapor pressure: 0.009 psia at 70F, flash point: 125F, Class II combustible liquid

Dimensions 8'-0" diameter by 25-4" long (double wall horizontal cylindrical)

Storage Capacity 12,000 gallons nominal capacity

Cleaning, Inspection, or Repair

No previous inspections or repairs have been performed

Foundation The tank is supported by steel saddles, each bearing down on the concrete tank pad

RPB/Leak Detection Continuous interstitial leak monitoring

Shell Construction The tank is double wall steel with seven lap-welded shell courses.

Tank heads are flat and lap-welded to the shell

Stairs/Ladders There is an individual ladder and small access platform for this tank.

Manholes (1) 24-inch manhole on top of tank shell w a/4-inch ATG mount

Interior Coating System Unknown

Exterior Coating System Appears to be DoD standard epoxy-polyurethane system

Level Gauging Moorman Bros mechanical tape gauge; Ronan ATG system

Overfill Protection/Level Alarms

High level alarm; Pump shut-off on high-high level

Piping 3-inch coated carbon steel from truck off-loading station; 3-inch coated carbon steel to refueler fillstand or vehicle dispenser

Venting/Vapor Emission Controls

3-inch Morrison Brothers pressure/vacuum vent, Fig 548. Vent settings were unreadable; 10-inch Morrison Brothers emergency vent, Fig 244, with a capacity of 495,000 cfh for both the primary tank and the interstitial space

Strapping Tables Generic manual strapping tables provided by tank manufacturer

Water Draw-Off/Product Recover System

N/A

Secondary Containment Double wall tank with continuous interstitial leak monitoring

Fire Protection System No fire protection present on tank (none is required); one fire hydrant was found within approximately 150 feet

Findings and Recommendations page 7

C. Findings and Recommendations

A major configuration issue which invalidates the double wall tank system as a means of secondary containment was noted as a potential Mandatory Deficiency. Aside from this issue, Tank Facility 900 was found to be in generally good condition. The tank is fully serviceable, but with several deficiencies that were not in full compliance with federal, state, and local regulations noted that require repair.

These noted deficiencies are listed below, with repair recommendations and a rough order of magnitude repair cost estimates. For basis of the cost estimate, it is assumed that the repairs will be completed by local action such as the Re-occurring Maintenance and Minor Repair program (RMMR). It should be noted that the recommendations for tank repairs below take into account the reported planned facility replacement project. If this replacement project is delayed or cancelled for any reason, the recommendations should be reevaluated on a cost to benefit basis. It is our overall recommendation that this replacement project be executed as soon as possible to relieve the issues that have been noted for this tank.

1. Mandatory Repairs

Mandatory repairs represent items that require immediate attention, in order to prevent imminent risk to system operators, equipment integrity, or the adjacent environment. If these repairs cannot be completed within a two-month period, the tank should be removed from service until the repairs are completed. There are no Mandatory Repairs currently required for this tank.

a. Secondary Containment

This tank features two 3-inch piping connections which are connected through the head of the tank, penetrating the double wall containment system. This configuration typically invalidates the double wall as a means of secondary containment. The adjacent truck containment may be adequate as a means of marginal secondary containment. A study could be performed to determine if this containment area is adequate. At this time, there is no recommended action, but if the planned tank replacement is delayed or cancelled, this containment issue will need to be addressed or the tank must be taken out of service or another means of secondary containment must be provided.

Estimated Cost: N/A

2. Recommended Repairs

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

The total Cost of the Recommended Repairs is $2,500.

Findings and Recommendations page 8

a. Mechanical Gauging

This tank is equipped with two different mechanical gauges, neither of which appear to be working properly. A new mechanical gauge should be provided to give the operators an easy way to verify tank contents against the ATG readings without having to stick the tank. A simple clock gauge, replacing the existing gauge would be recommended. Additionally, the existing tape gauge assembly should be disconnected from the tank and removed.

Estimated Cost: $1,000

b. Tank Platforms - Access

The existing tank platform provides access to the issue pump, gauging hatch, and several other appurtenances. However, the pressure vacuum vents, emergency vents, ATG, and interstitial leak sensor are not safely accessible via the platform. A self-supported platform should be provided to allow facility personnel to access all appurtenances. This recommendation may not be warranted due to the planned replacement project, as the existing access has been adequate for facility personnel have made up to this point.

Estimated Cost: N/A

c. Tank Platforms – Coating Repair

Some minor corrosion was noted at several locations on the tank ladder and access platform.

These areas should be cleaned, prepped, and a touch-up coating applied to prevent further corrosion of the material.

Estimated Cost: $1,000

d. Brush clearing

There is some brush growing adjacent to the tank which will potential damage the coating of the tank and makes it difficult for facility personnel to visually inspect the tank area. This brush should be removed by Base personnel.

Estimated Cost: $N/A

e. Tank Labeling

The existing tank is clearly labeled for tank product, capacity, and also includes no smoking warnings. However, there is no Hazardous Materials Identification Symbol per NFPA 704. The

HMIS diamond symbol should be added to this tank to clearly identify the health and flammability hazards.

Estimated Cost: $500

3. Other Noted Tank Items

Other Noted Items represent minor non-critical deficiencies that are not recommended for repair due to a prohibitive cost to benefit ratio or other reasons. If these repairs are deemed necessary by the stakeholders, fully replacing the tank should be considered as an alternative.

Findings and Recommendations page 9

a. Safety Clearances

Military Criteria requires a minimum of 50 feet of clearance from storage tanks to truck off-loading and loading facilities. At this facility, the tanks are immediately adjacent to the off-loading and loading stations. No action is recommended at this time to address this deficiency as a local agreement with the fire department has been established that the facility be manned at all times during use. Additionally, the existing tank is being programmed for total replacement in the near future. The new facility should meet all clearance requirements listed in NFPA 30, NFPA 30A, and applicable military criteria.

b. Access Manholes

UFC 3-460-01, Table 8-1.a requires all tanks of this configuration over 5,000 gallons to have two 36-inch access manholes. One of these manholes is required to include an internal ladder.

This repair is not recommended as the benefit of providing the new manholes and ladder does not justify the cost of the repair. The existing 24-inch manhole appears to be adequate for the

Activity’s operational needs.

c. Water Draw-Off Connection

UFC 3-460-01, Table 8-1.a requires all tanks of this configuration to have a 2-inch water draw-off connection with a double block-and-bleed valve for isolation. This repair is not recommended as the benefit of providing the larger water drain line with a double block-and-bleed valve does not justify the cost. The existing 1-inch drain line with ball valve appears to be adequate for the Activity’s operational needs.

4. Associated Site Upgrades

Site Upgrades are recommended upgrades to the site, which would still need to be addressed even if the tank were repaired or replaced. These items may be required by Federal, State and Local

Codes or by Military Criteria. Addressing these concerns typically falls under the jurisdiction of facility maintenance or utilities departments, not the tank repair program. There are no Associated

Site Upgrades currently recommended for this tank.

a. Fire Hydrants

There is only one fire hydrant located approximately 150 feet from the tank. Military Criteria require at least two fire hydrants be located within 300 feet of all storage tanks. If a fire water system upgrade is ever conducted at this facility, the addition of a second fire hydrant within

300 feet of the tanks should be included.

Inspection Photographs page 10

D. Inspection Photographs

Overview of Tank Facility 901. Note the Brush Growing up Against the Rear of the Tank

Overview of the Fueling Facility, Showing the Truck Off-Loading and Fillstand Area and the Tanks

Inspection Photographs page 11

Tank Appurtenances Including the ATG, Emergency Vents, and Pressure/Vacuum Vent

Tank Access Platform and Appurtenances

Inspection Photographs page 12

The Interstitial Drain Line and Issue and Receipt Piping Tank Connections

The Steel Tank Saddles Bear Directly on the Concrete Foundation Slab

Inspection Photographs page 13

The Tank Access Ladder and Platform; Several Appurtenances Are Not Safely Accessible

The Mogas Tanks Truck Off-Loading Station and Refueler Fillstand

Tank Configuration Sketch page 14

E. Tank Configuration Sketch

STI External Inspection Checklist page 15

Appendix ‘1’ – STI Formal External Inspection Checklist

Project Name : :

Project Site : :

Project Location : :

Tank Facility No. : :

Local Tank ID No. : :

Inspection Date : :

Design : UL

# Horizontal Vertical

Manufacturer : :

Dimensions : : Useable =

Construction Date : : N/A :

Construction : Bare Steel Single-Wall Insulated

Coated Steel # Double-Wall Galvanic or

Concrete Double-Bottom

Plastic/Fiberglass Lined :

Secondary

Containment : Earthen Dike Steel Dike

CRDM : N/A Yes

Release Prevention

Barrier : N/A Yes

Interior Coating : :

Piping : Issue : Size -

Material -

Connection Type -

Issue to -

Submitted to

Brockenbrough Job No.Dale County, Alabama 15-002.14

AST-990220

Fort Rucker

Inspector Name

General Inspection Information

Brown Minneapolis Tank

8'-0" diameter by 25-4" long Nominal =

Inspector Certification Number

Last Repair/Reconstruction

Type:

Date Installed

API

Rectangular

Other

Unknown

SWRI

Mogas (Type I)

Date Installed: Leak sensing probe

N/A2004 (estimated by facility personnel)

Concrete Synthetic Liner Other

Other

Impressed Current

Product

Capacity

Date Installed: Type:

Receipt from -

Receipt : Size -

Material -

Connection Type -

Unknown Exterior Coating Appears to be DoD standard epoxy-polyurethane system

Overfill Protection / Level Alarms: High level alarm; Pump shut-off on high-high level

Refueler fillstand or Vehicle dispenser

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

3-inch

Coated carbon steel

Butt-weld

Truck off-loading station

3-inch

Coated carbon steel

Butt-weld

N/A

Tank Specifications

Prior Inspection Date

SPCC Mandated Shop-Built AST Inspections

June 4th, 2015

N/A

12,000 gallons N/A

Cathodically Protected (Check one below)

Last Change of Service

Omaha District USACE

W9128F-12-D-0006Contract No.

Bryan Strayer

The interstitial space was found to contain 1'-4" of water. No fuel was noted.

Pad plates between the supports and shell are in good condition

Cracking or spalling

A

Good overall condition?

Wash-out Double wall tank with continuous interstitial leak monitoring probe

N/A

N/A

Corrosion A

A

X

N/A

A

Coating failure

Liquid present in the area?

Liner degradation

Leakage

Foreign materials present in the area

A

N/A

Check for :

Holes or cracks in wall or floor

A

A

X

7.1.8.1 Secondary

Containment

N/A

A

A

N/A

Secured properly on foundation or grade

7.1.7 Tank Supports

Welds are in good condition

Water drains away from tank

Corrosion or coating failure

Check for :

7.1.6 Tank Foundation

Record AST data and check for accuracy against actual conditions

Inspect against applicable industry standards

Review prior inspections, repairs and alterations data

Degradation

Ground slopes away from tank

Soil resting against/covering side of tank

A

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

ITEM

7.1 General

TASK STATUS COMMENTS

No previous inspections or repairs have been performed

Tank had a UL and manufacturer's nameplate. Both were fully readable

Check for :

The tank is constructed to UL Standard 142 for "Secondary Containment Aboveground Tank for Flammable Liquids"

A

A

A

7.1.3 Past Records

7.1.4 AST Nameplate Data

7.1.5 AST Fabrication

A

A

A

Exposed rebar

Wash-out or voids

Settlement

Cracking

NOTE: "A" IN THE STATUS COLUMN MEANS ACCEPTABLE; "X" IN THE STATUS COLUMN MEANS AN ITEM IS UNACCEPTABLE AND THERE IS A COMMENT.

A

The tank is supported by steel saddles, each bearing down on the concrete tank pad

The tank is supported by steel saddles, each bearing down on the concrete tank pad

Brush growing immediately adjacent to rear of tank

Ronan ATG system, with water probe and interstitial leak sensor

The tape gauge was unreadable and does not appear to be working.

The ATG gauging display is reportedly functioning properly, as are the associated level alarms

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

X

Check for :

Stress or leakage

Must be operable and in good condition?

A

This vent capacity is in compliance with the recommendations of STI SP001

Verify that the primary tank level gauge and secondary tank interstitial gauges move freely and the floats, guides, and attachments are in working order.

Moorman Bros mechanical tape gauge

A

X

A

Emergency vent covers

A

A

Liquid present in the area

COMMENTS

Good overall condition

Good overall condition

Leak detection probe for continuous monitoring of interstitial space

Interstitial space was found contain 1'-4" of water. No fuel was noted.

Associated piping was coated carbon steel and was found to be in fair condition.

A

Broken welds

A

7.1.9.2 Vents (Normal/

Emergency) and

Pressure/Vacuum Devices

3-inch Morrison Brothers pressure/vacuum vent, Fig 548. Vent settings were unreadable.

Vent could not be safely accessed.

10-inch Morrison Brothers emergency vent, Fig 244, with a capacity of 495,000 cfh for both the primary tank and the interstitial space

There is an individual ladder and small access platform for this tank.

Corrosion X

7.1.10 Tank Grounding &

Bonding

7.1.11 Stairways, Handrails, and Platforms

A Liquid level gauge length sized correctly for tank diameter?

Alarms are operable?

Strap secured and in good condition?

Check for :

A There is a grounding wire from a lug, welded to tank head, to the tank pad grounding grid

Adequate size and capacity?

This vent capacity is in compliance with the recommendations of STI SP001. Both vents were fully operable

A

A

A

Corrosion

Rusted bolted connections

Verify that components are moving freely and vent passageways are not obstructed for :

CRDM

Pressure/ vacuum vent poppets

Other moving vent components

A

7.1.9.1 Piping and Piping

Connections

Degradation

ITEM

7.1.8.3 Drain Valves N/A

TASK STATUS

N/A

Operable and in good condition?

A

A

7.1.8.2 Spill Control &

Bent members A

Coating Failure?

Ladder and platform are steel. The platform coating was failing at several locations, with some minor corrosion

Tank exterior coating was found to be in fair condition, but dirt and algae covered the top of the tank.

7.1.12 Tank Shell & Head

7.1.9.3 Tank Gauges

7.2.4 Average minimum thickness measurement

Location 1 (inch)

7.4.3 For Vertical ASTs :

Roof

Tank exterior coating was found to be in fair condition, but dirt and algae covered the top of the tank.

Most of the tank identification, product, and warning labels are present and fully readable.

Tank did not include the NFPA 704 Hazardous Materials Identification Symbol (HMIS)

Bulging

Exterior Corrosion

Distortion

Cracking

Check shell and ancillary equipment for:

Paint Failure N/A

Holes or corrosion N/A

Low areas and standing water N/A

Check the roof for :

7.2 Determine the original shell thickness of the AST

Suggested methods are :

Check shell plates and welds for : The tank is double wall steel with seven lap-welded shell courses. Tank heads are flat and lap-welded to the shell

TASK

Stress

Mechanical damage

7.3 Horizontal AST / 7.4 Vertical AST or Rectangular AST

A

A

A

A

A

A

A

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

7.2.2 Consult the tank manufacturer

7.2.1 Review the original tank documentation, such as drawings and packing lists

7.2.3 Exam the tank labels for evidence of a widely accepted tank standard. Consult the referenced standard to determine the minimum design shell thickness Original shell thickness assumed to be 0.25 inch

Location 2 (inch) Location 3 (inch) Location 4 (inch)

Measure the tank thickness of several areas of the tank that have no visible corrosion or pitting

Average thickness (inch)

ITEM

A

A

STATUS COMMENTS

7.3.1 / 7.4.1 Tank Shell, Heads, or Roof Dents A

Pinholes

Buckling

Distortion

A Check if leak detection equipment/ method is operating?

For leak detection equipment, check for:

7.5 Double-Wall AST or Double-Bottom AST

ITEM TASK STATUS COMMENTS

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

7.5.1 Leak Detection

Equipment / Method

Double-Wall ASTs do not require UT readings

7.5.3 Tank thickness

measurement:

STI SP001 FORMAL EXTERNAL INSPECTION (FEI) CHECKLIST

Additional Comments:

Leaks or presence of liquid in interstice?

The window is clean and clear in sight leak gauges

The wire gauges of electronic gauges for tightness and corrosion

A

N/A

A

7.5.2 Leaks

Operators report interstitial leak sensor is working properly

Interstitial space was found to contain 1'-4" water. No fuel was noted.

Activate the test button, if applicable N/A

5) There is one fire hydrant located approximately 150 feet from the tank.

1) The 3-inch inlet and outlet nozzles that penetrate the front head of the tank invalidate the double wall system as a means of secondary containment. Should there be a release, however, it will be capture by the adjacent truck transfer containment system. A detailed study of this containment to confirm enough capacity to contain a full tank should be conducted.

2) The truck loading and off-loading equipment is located immediately adjacent to the tank, which violates the required safety clearances. However, a local agreement with the security and safety office allows operation as long as the facility is constantly manned.

3) Although a ladder and platform are present, there are several tank appurtenances that are difficult to attend to. The platform only offers access to the pump and manual gauging hatch. All of the other appurtenance, including all vents, are inaccessible

4) There is brush growing immediately adjacent to the tank, which could damage the coating and makes visual inspection difficult. Brush should be cut away.

STI Monthly and Annual Checklists page 16

Appendix ‘2’ – STI Monthly and Annual Checklists

AST INSPECTION STANDARD 29 SEPTEMBER 2011

STI SP001 Monthly Inspection Checklist

General Inspection Information:

Inspection Date: Retain Until Date: (36 months from inspection date)

Prior Inspection Date: Inspector Name:

Tanks Inspected (ID #’s):

Inspection Guidance:

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified

Inspector. It shall be performed by an owner’s inspector who is familiar with the site and can identify changes and developing problems.

Upon discovery of water in the primary tank, secondary containment area, interstice, or spill container, remove promptly or take other corrective action. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly.

(*) designates an item in a non-conformance status. This indicates that action is required to address a problem.

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for 36 months.

In the event of severe weather (snow, ice, wind storms) or maintenance (such as painting) that could affect the operation of critical components

(normal and emergency vents, valves), an inspection of these components is required as soon as the equipment is safely accessible after the event.

Item Task Status Comments

1.0 Tank Containment

1.1 Containment

structure

Check for water, debris, cracks or fire hazard

�Yes* �No �N/A

1.2 Primary tank Check for water �Yes* �No

1.3 Containment

drain valves Operable and in a closed position

�Yes �No* �N/A

1.4 Pathways and

entry

Clear and gates/doors operable

�Yes �No* �N/A

2.0 Leak Detection

2.1 Tank Visible signs of

leakage

�Yes* �No

2.2 Secondary

Containment

Visible signs of leakage from tank into secondary containment

�Yes* �No

2.3 Surrounding soil Visible signs of

leakage

�Yes* �No �N/A

2.4 Interstice Visible signs of

leakage

�Yes* �No �N/A

AST INSPECTION STANDARD 30 SEPTEMBER 2011

3.0 Tank Equipment

3.1 Valves a. Check for leaks. �Yes* �No �N/A

b. Tank drain valves must be kept locked.

�Yes* �No �N/A

3.2 Spill

containment boxes on fill pipe

a. Inspect for debris, residue, and water in the box and remove.

�Yes* �No �N/A

b. Drain valves must be operable and closed.

�Yes* �No �N/A

3.3 Liquid level

equipment

a. Both visual and mechanical devices must be inspected for physical damage.

�Yes �No* �N/A

b. Check that the device is easily readable

�Yes �No* �N/A

3.4 Overfill

equipment

a. If equipped with a "test" button, activate the audible horn or light to confirm operation.

This could be battery powered. Replace the battery if needed

�Yes �No* �N/A

b. If overfill valve is equipped with a mechanical test mechanism, actuate the mechanism to confirm operation.

�Yes �No* �N/A

3.5 Piping

connections

Check for leaks, corrosion and damage

�Yes* �No

4.0 Tank Attachments and Appurtenances

4.1 Ladder and

platform structure

Secure with no sign of severe corrosion or damage?

�Yes �No* �N/A

5.0 Other Conditions

5.1 Are there other conditions that should

be addressed for continued safe operation or that may affect the site spill prevention plan?

�Yes* �No

AST INSPECTION STANDARD 31 SEPTEMBER 2011

Additional Comments:

AST INSPECTION STANDARD 32 SEPTEMBER 2011

STI SP001 Annual Inspection Checklist

General Inspection Information:

Inspection Date: Retain Until Date: (36 months from inspection date)

Prior Inspection Date: Inspector Name:

Tanks Inspected (ID #’s):

Inspection Guidance:

For equipment not included in this Standard, follow the manufacturer recommended inspection/testing schedules and procedures.

The periodic AST Inspection is intended for monitoring the external AST condition and its containment structure. This visual inspection does not require a Certified

Inspector. It shall be performed by an owner’s inspector who is familiar with the site and can identify changes and developing problems.

Remove promptly upon discovery standing water or liquid in the primary tank, secondary containment area, interstice, or spill container. Before discharge to the environment, inspect the liquid for regulated products or other contaminants and disposed of it properly.

In order to comply with EPA SPCC (Spill Prevention, Control and Countermeasure) rules, a facility must regularly test liquid level sensing devices to ensure proper operation (40 CFR 112.8(c)(8)(v)).

(*) designates an item in a non-conformance status. This indicates that action is required to address a problem.

Non-conforming items important to tank or containment integrity require evaluation by an engineer experienced in AST design, a Certified Inspector, or a tank manufacturer who will determine the corrective action. Note the non-conformance and corresponding corrective action in the comment section.

Retain the completed checklists for 36 months.

Complete this checklist on an annual basis supplemental to the owner monthly-performed inspection checklists.

Note: If a change has occurred to the tank system or containment that may affect the SPCC plan, the condition should be evaluated against the current plan requirement by a Professional Engineer knowledgeable in SPCC development and implementation.

1.0 Tank Containment

1.1 Containment

structure

Check for:

• Holes or cracks in containment wall or floor

• Washout

• Liner degradation

• Corrosion

• Leakage

• Paint failure

• Tank settling

�Yes* �No �N/A

2.0 Tank Foundation and Supports

2.1 Foundation Settlement or

foundation washout?

�Yes* �No

2.2 Concrete pad

or ring wall

Cracking or spalling? �Yes* �No �N/A

AST INSPECTION STANDARD 33 SEPTEMBER 2011

2.3 Supports Check for corrosion, paint failure, etc.

�Yes* �No �N/A

2.4 Water

drainage

Water drains away from tank?

�Yes �No* �N/A

2.5 Tank

grounding

Strap secured and in good condition?

�Yes �No* �N/A

3.0 Cathodic Protection

3.1 Gavlvanic

cathodic protection system

Confirm system is functional, includes the wire connections for galvanic systems

�Yes �No* �N/A

3.2 Impressed

current system

a. Inspect the operational components (power switch, meters, and alarms).

�Yes �No* �N/A

b. Record hour meter, ammeter and voltmeter readings.

�Yes �No* �N/A

4.0 Tank Shell, Heads, Roof

4.1 Coating Check for coating

failure

�Yes* �No

4.2 Steel

condition

Check for:

• Dents

• Buckling

• Bulging

• Corrosion

• Cracking

�Yes* �No

4.3 Roof slope Check for low points

and standing water

�Yes* �No �N/A

5.0 Tank Equipment

5.1 Vents Verify that

components are moving freely and vent passageways are not obstructed for:

• Emergency vent covers

• Pressure/vacuum vent poppets

• Other moving vent components

�Yes* �No

AST INSPECTION STANDARD 34 SEPTEMBER 2011

5.2 Valves Check the condition of

all valves for leaks, corrosion and damage.

�Yes* �No

5.2.1 Anti-siphon, check and gate valves

Cycle the valve open and closed and check for proper operation.

�Yes �No* �N/A

5.2.2 Pressure

regulator valve

Check for proper operation. (Note that there may be small, 1/4 inch drain plugs in the bottom of the valve that are not visible by looking from above only)

�Yes �No* �N/A

5.2.3 Expansion

relief valve

Check that the valve is in the proper orientation. (Note that fuel must be discharged back to the tank via a separate pipe or tubing.)

�Yes �No* �N/A

5.2.4 Solenoid

valves

Cycle power to valve to check operation.

(Electrical solenoids can be verified by listening to the plunger opening and closing. If no audible confirmation, the valve should be inspected for the presence and operation of the plunger.)

�Yes �No* �N/A

5.2.5 Fire and

shear valves

a. Manually cycle the valve to ensure components are moving freely and that the valve handle or lever has clearance to allow valve to close completely.

�Yes �No* �N/A

b. Valves must not be wired in open position.

�Yes �No* �N/A

AST INSPECTION STANDARD 35 SEPTEMBER 2011

c. Make sure fusible element is in place and correctly positioned.

�Yes �No* �N/A

d. Be sure test ports are sealed with plug after testing is complete and no temporary test fixture or component remains connected to valve.

�Yes �No* �N/A

5.3 Interstitial

leak detection equipment

Check condition of equipment, including:

• The window is clean and clear in sight leak gauges.

• The wire connections of electronic gauges for tightness and corrosion

• Activate the test button, if applicable.

�Yes �No* �N/A

5.4 Spill

containment boxes on fill pipe

a. If corrosion, damage, or wear has compromised the ability of the unit to perform spill containment functions, replace the unit.

�Yes* �No �N/A

b. Inspect the connections to the AST for tightness, as well as the bolts, nuts, washers for condition and replace if necessary.

�Yes* �No �N/A

c. Drain valves must be operable and closed

�Yes* �No �N/A

5.5 Strainer a. Check that the

strainer is clean and in good condition.

AST INSPECTION STANDARD 36 SEPTEMBER 2011

5.5 Strainer b. Access strainer

basket and check cap and gasket seal as well as bolts.

�Yes �No* �N/A

5.6 Filter a. Check that the filter

is in good condition and is within the manufacturer’s expected service life.

Replace, if necessary.

�Yes �No* �N/A

b. Check for leaks and decreased fuel flow

�Yes �No* �N/A

5.7 Flame

arrestors

Follow manufacturer’s instructions. Check for corrosion and blockage of air passages.

�Yes* � No �N/A

5.8 Leak detector

for submersible pump systems

Test according to manufacturer's instructions and authority having jurisdiction (AHJ).

Verify leak detectors are suited and properly installed for aboveground use.

�Yes �No* �N/A

5.9 Liquid level

equipment

a. Has equipment been tested to ensure proper operation?

�Yes �No* �N/A

b. Does equipment operate as required?

�Yes �No* �N/A

c. Follow manufacturer’s instructions

�Yes �No* �N/A

5.10 Overfill

equipment

a. Follow manufacturer’s instructions and regulatory requirements for inspection and functionality verification.

�Yes �No* �N/A

b. Confirm device is suited for above ground use by the manufacturer

AST INSPECTION STANDARD 37 SEPTEMBER 2011

6.0 Insulated Tanks

6.1 Insulation Check condition of

insulation for:

• Missing sections

• Areas of moisture

• Mold

• Damage

�Yes* � No �N/A

6.2 Insulation

cover or jacket

Check for damage that will allow water intrusion

�Yes* No �N/A

7.0 Miscellaneous

7.1 Electrical

wiring and boxes

Are they in good condition?

�Yes �No* �N/A

7.2 Labels and

tags

Ensure that all labels and tags are intact and readable.

Additional Comments:

1011 Boulder Springs Drive, Suite 200 Richmond, Virginia 23225

Phone: 804-592-3900 Fax: 804-592-3901 www.brockenbrough.com