Attachment K-1 - BRD-FY17-FAC 10418-TANK 2-FINAL.pdf

US Army Corps of Engineers Omaha District

API 653 Out-of-Service Inspection Report

Air National Guard, Bradley Field, Connecticut Facility 10418

Tank 2

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

USACE POL-MCX

6 July 2017

API 653 Out-of-Service Inspection Report ANG Bradley Field, East Granby, Connecticut

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

THIS INSPECTION

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES

GENERAL TANK INFORMATION

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

3. Previous Repairs

4. Future Projects

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Tank Foundation

3. Tank Shell

4. Tank Appurtenances

5. Tank Coating

6. Tank Piping System

7. Fire Protection System

8. Secondary Containment

C. FINDINGS AND RECOMMENDATIONS

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

2. SIGNIFICANT FINDINGS per API 653, UFC 3-460-01, or AW 78-24-27 Standards

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

4. REPAIRS to Fully Comply with API 653, UFC 3-460-01, or AW 78-24-27 Standards

APPENDIX A: SUB-CONSULTANT REPORTS

API 653 OUT-OF-SERVICE INSPECTION REPORT

APPENDIX B: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

AFFF Aqueous Firefighting Foam

API American Petroleum Institute

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

ATG Automatic Tank Gauge

BBL Barrel

CFR Code of Federal Regulations

CMU Concrete Masonry Unit

CP Cathodic Protection

DFT Dry Film Thickness

FAC Facility

HLA High Level Alarm

HLCS High Level Control Shutoff

HHLA High-High Level Alarm

LCV Level Control Valve

LLA Low Level Alarm

LLLA Low-Low Level Alarm

MFL Magnetic Flux Leakage

MT Magnetic Particle Testing

NA Not Applicable

NACE National Association of Corrosion Engineers

NDT Non-Destructive Testing

NFPA National Fire Protection Association

PSI Pounds per Square Inch

PT Penetrant Testing

PTFE Polytetrafluoroethylene (e.g., Teflon)

P/V Pressure/Vacuum

RP Recommended Practice

PST Product Saver Tank

TRV Thermal Relief Valve

UFC Unified Facilities Criteria

UFGS Unified Facilities Guide Specifications

UT Ultrasonic Testing

GENERAL SUMMARY

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

No. W9128F-12-D-0006 Delivery Order 0026 to perform SPCC Mandated API 653 Out-of-service (internal and external) Inspection of Tank Facility 10418, locally known as Tank 2, at Bradley Field Air National Guard Base in

East Granby, Connecticut. This inspection was completed on April 6, 2017 in accordance with API Standard 653, “Tank Inspection, Repair, Alteration, and Reconstruction,” and the referenced contract. The out-of-service inspection was performed by Brockenbrough and our sub-consultant, InterSpec, LLC (InterSpec). Following the tank inspection, the floating pan perimeter and penetration seals were replaced, as part of the current project.

Facility 10418 is a 32-foot and 9-inch diameter by 21-foot and 1-inch tall, single wall, vertical, field erected tank with a nominal storage capacity of 2,500 barrels of jet fuel (F-24). The tank manufacturer’s data plate indicates the tank was erected in 1993. The tank’s aluminum internal floating pan was manufactured by Petrex. The previous out-of-service (internal) inspection was performed in 2006.

Secondary containment is provided by a concrete dike basin and steel reinforced concrete dike walls. Details of tank construction and appurtenances are included in the Tank Information Table on page 6 and in Section ‘B’.

No Mandatory Repairs were identified during the inspection. Additional noted deficiencies are discussed in more detail in Section ‘C’, and should be addressed in a timely manner. Photographs of the deficiencies are also included in Section ‘C’. Our sub-consultant’s report is included in Appendix ‘A’. Additional photographs are included in

Appendix ‘B’.

The next API Standard 653 In-Service (visual external) Inspection should be performed by April 2022. The next ultrasonic thickness inspection of the shell should be performed by January 2032. While the current UFC 3-460-03 requires out-of-service inspection to occur every 10 years of service, an upcoming revision allows the frequency to be extended as determined by a certified API 653 tank inspector. While API would allow the inspection to be performed in 20 years, the tank is at higher risk of developing a leak due to the potential for galvanic internal corrosion caused by the presence of stainless steel internal piping and appurtenances. Therefore, we recommend the next API Standard 653 Out-Of-Service (internal and external) Inspection should be performed by April 2027.

This inspection should include an examination of the tank bottom by magnetic flux leakage (MFL or MFE) technology, and a thorough code compliance evaluation. Special attention should be paid to the area of the sump below the stainless steel water draw-off and low suction piping and other areas of the tank bottom that are near or below stainless steel appurtenances.

THIS INSPECTION

API Out-of-Service (internal and external) Inspection Date: 6 April 2017 Equipment Used:

(See sub-consultant report.)

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: June 2006 API In-Service (External) Inspection Date: NA

RECOMMENDED FUTURE INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: April 2037 (per API, and if stainless steel internals are eliminated)

April 2027 (per current UFC, or if stainless steel internals are not eliminated) API Ultrasonic Thickness Inspection of Shell Date: April 2032 API In-Service (External) Inspection Date: April 2022

Mike O’Connor Mechanical Designer API 653 Inspector No. 6230

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner Connecticut Air National Guard

Location ANGB Bradley Field

Facility Number 10418

Tank Number Tank 2

State / Country Connecticut / U.S.A.

City East Granby

Inspection Date April 6, 2017

Tank Manufacturer Witherup Fabrication and Erection, Inc.

Design Standard API 650 8th Edition

Date of Construction 1993

Tank Contents Jet fuel (F-24)

Tank Serial Number 05265A

Tank Diameter 32’-9”

Shell Height 21’-1”

Product Height 17’-0” (limited by overflow)

Tank Capacity 2,500 bbl nominal.

Foundation Concrete ringwall.

Construction

Bottom 1/4-inch butt-welded pie plate, cone down.

Shell Three shell courses: 1/4-inch butt-welded plate.

Floating Roof Petrex aluminum honeycomb pan.

Fixed Roof Supported cone roof made of 3/16-inch plate.

Material

Bottom Carbon steel of unknown grade.

Shell SA-36.

Floating Roof Aluminum honeycomb

Fixed Roof Carbon steel of unknown grade.

Cathodic Protection Impressed current.

Interior Coating System Interior 100% coated, likely epoxy.

Exterior Coating System Epoxy/polyurethane assumed.

Level Gauging Cameron ATG, Shand and Jurs Autogauge (tape gauge)

Overfill Protection Independent high and high-high, level alarms, float operated LCV

Piping Receipt 6” Stainless Steel

Issue 6” (12” nozzle) Stainless Steel

Low Suction 3” Stainless Steel

Water Draw-off 2” Stainless Steel

Level Alarms Independent high, high-high, low and low-low level alarms; ATG Alarms.

A. GENERAL PROJECT INFORMATION

1. API 653 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.

For FAC 10418 (Tank 2), an API Standard 653 Out-of‐service (internal and external) Inspection was performed. Following the tank inspection, the floating pan perimeter and penetration seals were replaced.

2. Site Information

On April 4 through 6, 2017 Brockenbrough performed API 653 Out-of‐service (internal and external)

Inspection of Facility 10418 (Tank 2) located at Bradley Field Air National Guard Base (ANGB). Bradley

Field is located on the East Granby side (westside) of the Bradley International Airport, AKA Hartford-

Springfield Airport, which is itself located in and bordered on the east by Windsor Locks, Connecticut.

Bradley ANGB is home to the 103rd Airlift Wing, which was established 1 November 1923 as the 118th

Observation Squadron. The 118th Airlift Squadron's origins date to August 1917, when the unit was activated as the 118th Aero Squadron at Kelly Field, Texas. The 103rd Airlift Wing currently operates the C-130H Hercules, a four engine turboprop aircraft, under the Air Mobility Command, and its mission is to provide cargo and passenger airlift. Dubbed “The Flying Yankees", the 103rd Airlift Wing is the third oldest Air National Guard unit in the United States, tracing their lineage back over 90 years of military aviation.

3. Previous Repairs

At some time in the past, the original Varec servo level gauge was abandoned and a Cameron ATG was installed in the manual gauge well.

4. Future Projects

Per facility personnel, the emergency fuel shut off (EFSO) switches near the tank are being replaced.

https://en.wikipedia.org/wiki/103d_Airlift_Wing https://en.wikipedia.org/wiki/118th_Observation_Squadron https://en.wikipedia.org/wiki/118th_Observation_Squadron https://en.wikipedia.org/wiki/Kelly_Field https://en.wikipedia.org/wiki/103d_Airlift_Wing https://en.wikipedia.org/wiki/C-130H_Hercules https://en.wikipedia.org/wiki/Air_Mobility_Command

B. TANK INSPECTION COMMENTS

1. Tank Construction

FAC 10418 is a nominal 2,500 bbl, 32‐foot and 9-inch diameter by 21-foot and 1-inch tall, Jet Fuel (F‐

24) aboveground vertical storage tank. The tank erector’s nameplate indicates the tank was originally constructed by Witherup Fabrication and Erection, Inc. in 1993, and the standard of construction is API

650 8th Edition. The tank was built with a cone down bottom, Petrex aluminum honeycomb internal floating pan, and a center bottom sump. Following the tank inspection and as part of the current project, the floating pan foam log perimeter and penetration seals were replaced with flexible double wiper squeegee seals.

2. Tank Foundation

The tank rests on an 18-inch high concrete ringwall foundation. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. No problems were noted with the foundation. A shell settlement survey was performed during the inspection in accordance with Appendix B of API Standard 653. The shell settlement evaluation indicates the settlement of the bottom of the shell and perimeter of the tank bottom is acceptable. The measurements and analysis are recorded in our sub-consultant’s report.

3. Tank Shell

The vertical and cylindrical shell consists of three butt‐welded courses. The exterior of the shell was visually inspected and evaluated for plumbness, roundness, peaking and banding. The shape of the shell appears to be within the allowable tolerances of API Standard 653. The coating was evaluated for deterioration. The ultrasonic thickness measurements of the shell and calculations included in

Appendix A indicate the shell has more than 30 years of remaining life. The interior and exterior of the shell are coated. The interior shell coating shows no sign of significant deterioration. There are isolated coating failures on the exterior of the tank bottom extension and exterior of the shell. API 653 recommends ultrasonic thickness measurements of the shell be taken at least every 15 years.

4. Tank Appurtenances

a. Tank Roof

The tank’s steel, lap welded cone roof is covered with mold and algae and has numerous areas of coating failure and corrosion. There are also leaves and debris under the edges of the perimeter vent inspection hatches which also promote corrosion.

b. Internal Floating Pan

The tank’s internal floating pan was manufactured by Petrex. Following the tank inspection, and as part of the current project, the floating pan foam log perimeter and wiper penetration seals were replaced with flexible double wiper squeegee seals.

c. Venting

The 2-foot diameter roof center vent, is covered with insect screen. API 650 does not allow insect screen on vents as this significantly reduces the ventilation capacity and is subject to clogging.

d. Gauging

The tank’s original Varec servo level ATG is installed in a 10-inch stainless steel stilling well and is abandoned. A Cameron ATG is installed (retrofitted) in the 8-inch manual gauging nozzle, which is installed through a 24-inch manhole cover. The Cameron ATG chain and tubing components penetrate the floating pan through a target cone below the manual gauge hatch. There is no means of performing accurate manual gauging with the ATG blocking the gauging hatch and target cone.

e. Level Alarms

The tank has independent (shell mounted) high, high-high, low, and low-low level alarms.

However, there is no access to the high level alarms for testing and maintenance; and the alarms are not plumbed to allow testing.

f. Stairs, Landings and Ladders

The tank’s steel cone roof is accessible by a circumferential stairway mounted on the shell of the tank. The circumferential stairway step rise is generally 9 and 1/4 inches. Contrary to OSHA, the bottom stairway step is approximately 28 inches above the dike basin, and a stack of 8-inch heavy concrete masonry blocks are placed below the bottom step to provide non-compliant access to the stairway bottom step. The circumferential stairway incudes an intermediate landing for accessing the upper shell manhole floating pan at high leg position. However, contrary to OSHA there is only

13 inches of clearance between the manhole cover handles and the landing/stairway handrail.

There is no ladder on the interior of the tank. DoD Standard Design AW 78-24-27 and UFC 3-460-

01 Table 8-1 Item i) require an internal ladder. As the tank is smaller than the smallest tank included in AST Standard, providing an internal ladder is not recommended.

g. Grounding and Bonding

There are four grounding cables connected to ground lugs welded to the tank shell. The grounding cables penetrate the secondary containment through unsealed conduit.

h. Shell Manhole

The weld attaching the outer/periphery shell manhole reinforcing plate to the shell is approximately 2 inches from the shell to bottom weld. API 650 requires a weld spacing of at least three inches, unless the weld is tested in accordance with API 650. The manufacturer’s nameplate certifies the tank as being built to API 650, which implies all the required tests were performed.

Therefore, no additional examinations or tests are required at this time. There is only one shell manhole. DoD Standard Design AW 78-24-27 and UFC 3-460-01 Table 8-1 Item f) require two shell manholes. However, the tank is smaller than the smallest tank included in the AST Standard.

Therefore, modification is not recommended

5. Tank Coating

There is mold and algae on the shell, roof, and appurtenances. There are numerous areas of coating failure on the cone roof and on the tank’s appurtenances. The tanks isolation valves are corroded.

There are isolated areas of coating failure on the tank shell and tank bottom extension. The exterior coating is 24 years old. The interior is 100% coated. The interior coating on the frame of the pan installation hatch is failed. There is some minor staining of the underside of the roof and interior of the shell above the floating pan. The interior coatings otherwise appear to be in good condition. The internal and external coatings are currently approximately 24 years old.

6. Tank Piping System

Fuel is received into the tank from the nearby truck off-load stand via the filter/pumphouse and is issued from the tank through the filter/pumphouse to a truck fillstand. The interior 6-inch diffuser, 12-inch issue, 3-inch low suction and 3/4 -inch piping and interior pipe supports are stainless steel. The suction terminates over the sump with an antivortex plate, limiting access to the sump for inspection.

7. Fire Protection System

There is an aqueous firefighting foam system connected by piping to a foam chamber on the top shell course. There is no foam dam on top of the floating pan. There are also no fire hydrants within 300 feet of the tank. The nearest fire hydrants are approximately 650 feet from the tank. Fire department personnel indicated they do not regularly test the AFFF system, but want to keep it.

8. Secondary Containment

The tank sits within a concrete secondary containment. The concrete walled secondary containment has a locked drain valve for drainage. The dike drain sump and piping to the drain valve were filled with water and observed for any change in the level of the water, which would indicate a leak. No change in the level of the water in the secondary containment drain sump was noted.

The concrete secondary containment basin is sloped toward a swale located approximately 7 feet from the tank and drains to a sump located in the northeast corner of the secondary containment. The receipt piping passes over the swale east of the tank and the issue piping passes over the swale northwest of the tank. NFPA 30 paragraph 22.11.2.1 requires the dike basin to be sloped away from the tank for a distance of 50 feet or to the dike wall, whichever is less. NFPA 30 paragraph 22.12.2.1 requires the dike basin to also be sloped away from the piping for a distance of 50 feet.

The grounding cables penetrate the secondary containment through unsealed conduit. The dike basin appears to be scored to control cracking, but there are no seals in the joints. The dike basin-to-foundation and dike basin-to-dike wall seals are failed. There are approximately 8 feet of uncontrolled and unsealed cracking in the dike basin. There are approximately 12 feet of unsealed cracks in the dike walls. There is an imbedded steel projection in the dike area that is a tripping hazard. There are leaves and debris in the dike area.

The volume of the secondary containment is sufficient to hold the contents of the tank full to the bottom of the overflow as required by NFPA 30 plus 5 inches of free board. UFC 3-460-01 requires 12 inches of freeboard for new tanks.

C. FINDINGS AND RECOMMENDATIONS

Tank Facility 10418 was found to be in generally fair condition. However, there is one issue with the floating pan that is not in compliance with military criteria and that prevented the Government from immediately returning the tank to service. The Government decided to treat the issue with the floating pan as a Mandatory Repair. The tank is otherwise fully serviceable, with no other deficiencies that would require addressing before the tank is returned to service. There were also several items observed, that are not in full compliance with federal, state, and local regulations or other military criteria.

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, or the adjacent environment. The tank would have to be taken out-of-service to complete these repairs. No Mandatory Repairs are required to be performed.

2. SIGNIFICANT FINDINGS per API 653, UFC 3-460-01, or AW 78-24-27 Standards

The following information identifies the significant findings found during the tank inspection, and includes repair recommendations.

a. Demolish the Shell Mounted Thermometer Well

OBSERVATION: There is an abandoned thermometer well on the interior of the shell, with a threaded and plugged nozzle on the exterior.

REFERENCE: UFC 3-460-01 and DoD Standard Design AW 78-24-27 do not require shell mounted thermometer wells on fuel storage tanks.

RECOMMENDATION: Demolish the shell mounted thermometer well and nozzle.

b. Eliminate Stainless Steel Internal Components

OBSERVATION: The issue, receipt and low suction nozzles, internal piping, internal pipe supports, stilling well, floating pan leg striker plates, and floating pan support legs are stainless steel. The weld spacings of the internal pipe support base plates are not in accordance with API 650. The use of dissimilar metals can cause galvanic corrosion. The supports for the receipt diffuser do not touch the tank bottom and do not have base plates. The concentration of and rate of the galvanic corrosion (corrosion due to dissimilar metals) is typically much higher on metal surfaces under flaws in coatings than on surfaces that are generally uncoated. The tank is at higher risk of developing a leak due to the potential for galvanic internal corrosion caused by the presence of

Thermometer Well stainless steel internal piping and appurtenances. The suction terminates over the sump with an antivortex plate, limiting access to the sump for inspection. The stainless steel floating pan striker plates are glued to the tank bottom.

REFERENCE: UFC 3-460-01 Section 2-12.3.3 prohibits the bonding of dissimilar metals. UFC 3-460-

01 Paragraph 9-8 l) requires connecting dissimilar metals with isolation flanges. DoD Standard

Design AW 78-24-27 requires shell nozzles and internal pipe supports to be made of carbon steel;

internal piping, diffusers, stilling wells and floating pan support legs to be made of aluminum;

floating pan support legs to have PTFE feet, and the suction to terminate approximately half way between the sump and the shell. API 650 does not allow glue on striker plates. UFC 3-460-01

Section 2-12.3.3 prohibits the bonding of dissimilar metals.

RECOMMENDATION: The following should be accomplished at the next tank outage.

• Replace the stainless steel shell nozzles with carbon steel.

• Provide isolation flange kits between the external piping and the new carbon steel tank nozzles.

• Replace the internal stainless steel piping and diffuser with aluminum.

• Replace the stainless steel internal pipe supports and their base plates with carbon steel supports and API compliant base plates.

• Replace the floating pan stainless steel support legs with aluminum, remove the stainless steel floating pan support leg striker plates, and provide PTFE feet on the support legs.

• Repair the tank bottom coating where it is disturbed by the repairs.

c. Provide Davits

OBSERVATION: The shell manhole covers do not have davits to assist in opening and supporting the covers.

REFERENCE: DoD Standard Design AW 78-24-27 requires the lower shell manhole to have a davit to support the cover and assist in opening.

RECOMMENDATION: Provide davits on the upper and lower shell manhole covers.

d. Relocate Nozzle Isolation Valves to Shell Nozzles

OBSERVATION: The receipt and issue isolation valves are separated from the tank shell by spool pieces, which have branch connections for the thermal relief piping. In addition, there is no isolation valve upstream and adjacent to the level control valve.

REFERENCE: NFPA 30 – 22.13.1 requires the isolation valves to be located as close to the shell of the tank as practical. DoD Standard Design AW 78-24-27 requires the isolation valves to be on the tank nozzles and the thermal relief piping to be routed to a branch connection on the nozzle neck. UFC

3-460-01 paragraph 7-6.3.4 and DoD Standard Design AW 78-24-27 require an isolation valve upstream and adjacent to the level control valve.

RECOMMENDATION: Relocate the shell nozzle isolation valves to the shell nozzles, route the thermal relief piping to the nozzle necks, and provide an isolation valve upstream of and adjacent to the level control valve.

e. Modify Thermal Relief Piping

OBSERVATION: The receipt and issue thermal relief piping is threaded, includes sight flow indicators, and does not include testing tees. The thermal relief valves are set at 250 psi, which seem to be set a bit high even considering the positive displacement receipt pumps.

REFERENCE: UFC 3-460-01 paragraph 9-3.5 requires TRV piping around piping isolation valves;

paragraph 9-3.5.1 does not allow site flow indicators on thermal relief valve piping; paragraphs 9-8

e) and j) do not allow threaded piping, and UFC 3-460-03 paragraph 6-6.3.1 requires TRV testing be performed annually. DoD Standard Design AW 78-24-27 requires testing tees on thermal relief piping.

RECOMMENDATION: Perform a thermal relief study of the system. Modify the thermal relief piping to eliminate threaded piping (provide welded or flanged connections), eliminate the site flow indicators, provide testing tees, provide thermal relief valves with appropriate settings.

f. Service the Mechanical Tape Level Gauge

OBSERVATION: The mechanical tape level gauge appears operational, but the bump checker is not engaging.

REFERENCE: UFC 3-460-01 Table 8-1, Item o, and DoD Standard Design AW 78-24-27 require new storage tank designs to include a mechanical tape level gauge.

RECOMMENDATION: Service the mechanical tape level gauge and ensure the bump checker is properly engaging the tape.

Bump Checker

Tape Level Gauge

g. Provide Aluminum Stilling Wells

OBSERVATION: The tank’s original but now abandoned Varec servo level ATG is installed in a 10-inch stainless steel stilling well. A Cameron ATG is installed (retrofitted) in the 8-inch manual gauging nozzle, which is installed through a 24-inch manhole cover. The Cameron ATG chain and tubing components penetrate the floating pan through a target cone below the manhole cover and manual gauge hatch. There is no means of performing accurate manual gauging with the ATG blocking the gauging hatch and target cone. There is no water bottom sensor well.

REFERENCE: The DoD Standard AST Design AW 78-24-27 and UFC 3-460-01 Table 8-1, Item (f) requires an 8-inch fully slotted aluminum stilling well installed in a 10-inch nozzle for the ATG.

The DoD Standard AST Design AW 78-24-27 and UFC 3-460-01 Table 8-1, Item (f) requires a 6-inch aluminum stilling well installed in an 8-inch nozzle near the sump for a water bottom sensor. The

DoD Standard AST Design AW 78-24-27 and UFC 3-460-01 Table 8-1, Item (t) require an 8-inch fully slotted aluminum stilling well installed in a 10-inch nozzle for manual gauging and sampling.

RECOMMENDATION: Demolish the abandoned Varec ATG and portion of the 10-inch stainless steel stilling well 2 inches below the cone roof. Install through the 10-inch nozzle, an 8-inch aluminum stilling well with a gauge hatch for manual gauging and sampling. Provide an 8-inch fully slotted aluminum stilling well installed through a 10-inch roof nozzle for the ATG, and reinstall the ATG in the new well. Provide a 6-inch aluminum stilling well installed in an 8-inch nozzle near the sump for a water bottom sensor.

h. Provide Proper Stairway and Relocate Alarms and Controls to Provide Access

OBSERVATION: The level control float chamber is at a higher level than the high-high level alarm.

The high level alarm and control float chambers are not located near, and are not accessible from, the stairway for maintenance and testing, and there is no intermediate landing in the stairway for accessing alarms and controls. The landing for accessing the upper shell manhole and floating pan is not large enough to allow safely opening the manhole cover or for allowing OSHA compliant passage to the stairway above the manhole (only 13 inches of clearance between the manhole cover handles and the railing). The typical rise of the stairway steps is 9 1/4 inches. The bottom step of the stairway is 28 inches above the dike basin. A 16-inch high stack of 8-inch CMU blocks are placed below the bottom step to provide non-compliant access to the stairway bottom step.

REFERENCE: UFC 3-460-01, Item (l) and DoD Standard Design AW-78-24-27 require the level control float to actuate between the high level alarm and the high-high level alarm. UFC 3-460-01, Item (k), requires a stairway for accessing alarms and controls. DoD Standard Design AW 78-24-27 requires the high level alarm and high level control float chambers to be accessible from the stairway intermediate landing. OSHA regulation 29CFR1910.24 (d) requires the minimum width of stairs to be 22 inches. OSHA regulation 29CFR1910.24 (f) requires the rise and run of stair steps to be uniform from base to top.

RECOMMENDATION: Replace the existing circumferential stairway with a stairway that is compliant with OSHA and the DoD Standard AST Design AW 78-24-27, having lower, intermediate and a top landing. Relocate the high level alarm and level control float chambers to be accessible from the new intermediate stairway landing, and at levels per the DoD Standard AST Design AW 78-24-27.

Level Control Float High Level Alarm

i. Demolish Foam Chamber and Piping

OBSERVATION: There is an aqueous firefighting foam system connected by piping to a foam chamber on the top shell course. There is no foam dam on top of the floating pan. There are also no fire hydrants within 300 feet of the tank. The nearest fire hydrants are approximately 650 feet from the tank. Fire department personnel indicated they do not regularly test the AFFF system, but want to keep it. The top cover of the foam chamber is corroded shut to the chamber.

REFERENCE: UFC 3-460-01 and NFPA 30 do not require AFFF for Class II liquids.

RECOMMENDATION: If local authorities do not object, demolish the AFFF chamber, piping, supports, and brackets. If the abandoned AFFF system is not demolished; replace the diaphragm on the interior of the foam chamber, clean the air intake screens on the foam chamber, replace the coating on the foam chambers; and establish a regular program of inspection and testing of the foam system.

j. Replace External Coatings

OBSERVATION: There is mold and algae on the shell, roof, and appurtenances. There are numerous areas of coating failure on the cone roof and on the tanks appurtenances. There are isolated areas of coating failure on the tank shell and tank bottom extension. The exterior coating is 24 years old.

REFERENCE: UFC 3-460-01 paragraph 8-3.10 requires the exterior to be coated.

RECOMMENDATION: Replace the coatings on the exterior of the tank and appurtenances.

k. Replace Body Cavity Relief piping and Valves

OBSERVATION: The downstream body cavity relief isolation valve on the issue DBB tank isolation valve is stuck closed and inoperable. As a result, the issue DBB valve is nearly inoperable and excessive force must be used to open it.

REFERENCE: UFC 3-460-01 section 9-3.5 requires thermal relief for piping and valves to relieve the internal cavity of DBB valves.

RECOMMENDATION: Replace the downstream body cavity thermal relief valve isolation valve on the issue DBB tank isolation valve.

l. Replace Roof Center Vent Screen

OBSERVATION: The screen on the 2-foot diameter roof center vent is insect screen. Insect screen significantly reduces the ventilation capacity and is subject to clogging.

REFERENCE: API 650 paragraph H-5.2.2 requires vent screen with 1/2-inch openings.

RECOMMENDATION: Replace the insect screen on the roof center vent with bird screen with 1/2-inch openings.

m. Provide a Tank Bottom to Foundation Seal

OBSERVATION: There is no tank bottom to foundation seal.

REFERENCE: DoD Standard Design AW 78-24-27 requires the tank bottom to be sealed to the foundation. UFC 3-460-03 paragraph 8-4.1 B., requires the tank bottom-to-foundation seal to be inspected and maintained.

RECOMMENDATION: After the coating on the underside and edge of the tank bottom extension is cured, provide a tank bottom to foundation seal.

n. Repair the Secondary Containment

OBSERVATION: The grounding cables penetrate the secondary containment through unsealed conduit. The dike basin appears to be scored to control cracking, but there are no seals in the joints.

The dike basin-to-foundation and dike basin-to-dike wall seals are failed. There is approximately 8 feet of uncontrolled and unsealed cracking in the dike basin and approximately 12 feet of unsealed cracks in the dike walls. There is an imbedded steel projection (tripping hazard) in the dike area.

REFERENCE: NFPA 30 paragraph 22.11.2.4 and CFR 112.7(c)(1) require dike areas to be liquid tight.

RECOMMENDATION: Provide seals in the ground cable conduits. Replace all joint seals in the secondary containment basin and walls, approximately 800 linear feet. Provide approximately 300 liner feet of joint sealant where the dike basin appears to be scored to control cracking. Seal 8 feet of uncontrolled and unsealed cracking in the dike basin and 12 feet of unsealed cracks in the dike walls. Remove the tripping hazard.

o. Provide a Product Saver Tank

OBSERVATION: The water draw-off is hard piped to an underground product recovery tank located outside the dike area.

REFERENCE: DoD Standard Design AW 7-24-27 and UFC 3-460-01 paragraph 8-3.14.3 require the water draw-off connection to be piped to a product saver tank. The product saver tank may be piped to a product recovery tank. Connecting the fuel storage tank directly to a product recovery tank outside the secondary containment could potentially result in an uncontrolled spill.

RECOMMENDATION: Provide a product saver tank. Connect the water draw-off to the new product saver tank. Connect the product saver tank drain to the product recovery tank.

p. Provide Fire Hydrants

OBSERVATION: The nearest fire hydrant is approximately 650 feet from the tank.

REFERENCE: UFC 3-460-01 2-15.2.1 requires a minimum of two fire hydrants within 300 feet of the tank.

RECOMMENDATION: Provide two fire hydrants within 300 feet of the tank.

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

Recommended repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. Apply an Algaecide on a Regular Basis

OBSERVATION: There is mold and algae growing on the roof, shell, and appurtenances. The mold and algae may cause degradation of the exterior coating.

REFERENCE: UFC 3-460-01 paragraph 8-3.10 requires the exterior of fuel storage tanks to be coated.

RECOMMENDATION: Replacing the exterior coatings is recommended in the Significant Findings section. However, power washing the tank roof and application of an algae and mold/algae inhibitor of the exterior of the tank should be repeated on a regular basis.

b. Remove Debris

OBSERVATION: The melting of this past winter’s snow left behind a collection of dirt, leaves and plant debris in the dike area. Also, due to the proximity of the trees, leaves and other debris collects on the roof perimeter vent hoods, which could cause corrosion.

REFERENCE: NFPA 30 – 15.3.7 requires that storage areas shall be kept free of weeds, debris, and other combustible materials. UFC 3-460-01 paragraph 8-3.10 requires the exterior of fuel storage tanks to be coated.

RECOMMENDATION: Remove plant debris from the dike area and top of the tank, especially from under the perimeter vent hoods, and power wash the tank and the dike area on a regular basis.

4. REPAIRS to Fully Comply with API 653, UFC 3-460-01, or AW 78-24-27 Standards

These items represent repairs and/or upgrades that could be performed to bring the tank into full compliance with current standards, but that do not represent potential risks to system operators, equipment integrity, or the adjacent environment. Our recommendations to perform, or not to perform these repairs and/or upgrades, take into consideration the cost of the repair, the operational benefit of the repairs, the age of the tank/system, operator safety, environmental risks, and equipment integrity.

a. Replace Secondary Containment Basin with a Properly Sloped Basin

OBSERVATION: The dike basin slopes away from the tank to a swale approximately 8 feet from the tank. The receipt and issue piping cross over the swale.

REFERENCE: NFPA 30, paragraph 22.11.2.1 requires the dike basin to be sloped away from the tank for a distance of 50 feet or to the dike wall, whichever is less. NFPA 30, paragraph 22.12.2.1.

requires the dike basin to be sloped away from the piping.

RECOMMENDATION: Replace the concrete secondary containment basin with a basin sloped away from the tank all the way to the dike berm and away from the piping in accordance with NFPA 30.

b. Provide Scaffold Cable Supports

OBSERVATION: There are no scaffold cable supports on the fixed roof.

REFERENCE: UFC 3-460-01, Table 8-1, Item ff, and DoD Standard Design AW 78-24-27 require scaffold cable supports on the fixed roofs of new storage tanks.

RECOMMENDATION: Provide two scaffold cable supports on the fixed roof.

Swale ain

Swale

c. Provide a Filler Drum

OBSERVATION: The lower shell manhole cover does not have a filler drum.

REFERENCE: DoD Standard Design AW 78-24-27 requires the lower shell manhole cover to have a filler drum.

RECOMMENDATION: Provide the lower shell manhole cover with a filler Drum.

d. Provide Additional Secondary Containment

OBSERVATION: The volume of the secondary containment is sufficient to hold the contents of the tank full to the bottom of the overflow as required by NFPA 30 plus 5 inches of free board.

REFERENCE: UFC 3-460-01 requires 12 inches of freeboard for new tanks. UFC 3-460-01 paragraph

8-14.1 allows groups of tanks with a combined capacity of 15,000 bbl and with individual capacities not larger than 10,000 bbl to share a common dike area.

RECOMMENDATION: Provide additional secondary containment. This may be achieved by removing a portion of the dike wall between Tank Facility 10418 and the adjacent tank.

APPENDIX A: SUB-CONSULTANT REPORTS

API 653 OUT-OF-SERVICE INSPECTION REPORT

ER-US AIR FORCE - BRADLEY FIELD ANG - 103RD AIRLIFT WING-EAST GRANBY, CT-TANK#2-APRIL/2017

Inter Spec LLC Environmental Inspection Services 464 S Independence Blvd, C-104, Virginia Beach, VA 23452 www.interspecllc.net

Office: 757-622-6299 Fax: 757-622-9103

Toll Free: 800-546-7853

API-653 Engineering Inspection Report Tank # 2

US Air Force - Bradley Field ANG - 103rd Airlift Wing; East Granby, CT

Prepared for Austin Brockenbrough & Associates, L.L.P.

April 4,2017

API Standard 653 recommends this document containing valuable historical information be retained for the life of the tank.

Signature(s):

Gary G. Boley, Senior Inspector, API-653 # 020, API-570 # 267, API-510 # 2659

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 2

Executive Summary

An API Standard 653 Out-of-Service inspection of Tank # 2 was completed on April 4, 2017 to evaluate the tank’s integrity, collect data, and establish a database for future inspections and evaluations. A service life evaluation performed on the tank shows it as having greater than 30 years of remaining shell life under current conditions. Inspection Results are listed in section 4.1. Maintenance Recommendations are listed in section 4.2. Compliance Requirements are listed in section 4.3. All engineering calculations are provided in Appendix A.

The tank does not meet the compliance requirements mandated by federal, state, and/or local regulatory bodies. Refer to Compliance Requirements section 4.3 for details.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 3

Table of Contents

1.0 Introduction

1.1 Purpose

2.0 References

2.1 American Petroleum Institute

2.2 American Society of Mechanical Engineers Codes

2.3 National Association of Corrosion Engineers

2.4 National Fire Protection Association

2.5 American Society of Nondestructive Testing

2.6 Code of Federal Regulations

3.0 Description

3.1 Job Description

3.2 Tank Description

3.3 Service Description

3.4 Part Description

3.5 Joint Type Description

3.6 Inspection Description

3.7 Equipment Description

4.0 Inspection

4.1 Results

4.2 Maintenance Recommendations

4.3 Compliance Requirements

5.0 Serviceability

List of Appendices

A Engineering Calculations ................................................................................................................ A-1

B Engineering Drawings. .................................................................................................................... B-1

C Tank Historical Review ................................................................................................................... C-1

D API Checklists.................................................................................................................................. D-1

E Photographs ...................................................................................................................................... E-1

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 4

1.0 Introduction

1.1 Purpose:

1.1.1 This report presents an analysis of data collected during an inspection conducted on April 4, 2017 for Tank # 2, servicing Jet A, located at the US Air Force - Bradley Field ANG - 103rd Airlift Wing facility in East Granby, CT. The inspection was performed by a certified API-653 inspector. This report summarizes the results of the inspection meeting the requirements of API Standard 653 and API-650 8th Edition Appendix H. The primary and secondary containments including the supports, foundation, vents, gauges, and appurtenances were evaluated. The inspection was conducted by InterSpec, LLC.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 5

2.0 References

2.1 American Petroleum Institute (API):

2.1.1 API Standard 650, Welded Steel Tanks for Oil Storage

2.1.2 API Standard 653, Tank Inspection, Repair, Alteration, and Reconstruction

2.1.3 API RP 652, Lining of Aboveground Petroleum Storage Tank Bottoms

2.1.4 API RP 651, Cathodic Protection of Aboveground Petroleum Storage Tanks

2.1.5 API RP 575, Inspection of Atmospheric and Low-Pressure Storage Tanks

2.1.6 API RP 577, Welding Inspection and Metallurgy

2.1.7 API RP 2000, Venting Atmospheric and Low Pressure Storage Tanks

2.1.8 API Standard 570, Piping Inspection Code: Inspection, Repair, Alteration, and Rerating of In-

Service Piping Systems

2.2 American Society of Mechanical Engineers Codes (ASME):

2.2.1 ASME Boiler and Pressure Vessel Code; Section V, Non-Destructive Examination

2.2.2 ASME Boiler and Pressure Vessel Code; Section IX, Welding and Brazing Qualifications

2.2.3 ASME B31.3, Process Piping

2.3 National Association of Corrosion Engineers (NACE):

2.3.1 NACE Recommended Practice, RP0288-94, Inspection of Linings on Steel and Concrete

2.4 National Fire Protection Association (NFPA):

2.4.1 NFPA-30, 2012 Ed., Flammable and Combustible Liquids Code

2.4.2 NFPA-70, 2011 Ed., National Electrical Code

2.4.3 NFPA-780, 2008 Ed., Standard for the Installation of Lightning Protection Systems

2.5 American Society of Nondestructive Testing (ASNT):

2.5.1 ASNT-SNT-TC-1A

2.6 Code of Federal Regulations:

United States Department of Labor, Occupational Safety & Heath Administration

2.6.1 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part 1910, Subpart H, Section 119, Process safety management of highly hazardous chemicals

2.6.2 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part 1910, Subpart J, Section 147, The control of hazardous energy (lockout/tagout)

2.6.3 CFR, Title 29, Subtitle B, Volume 5, Chapter XVII, Part 1910, Subpart S, Section 331-335, Safety-Related Work Practices

United States Environmental Protection Agency

2.6.4 CFR, Title 40, Volume 21, Chapter I, Subchapter D, Part 112, Oil Pollution Prevention

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 6

3.0 Description

3.1 Job Description:

Job Number: 16-0913 Contracted by: Austin Brockenbrough & Associates

3.2 Tank Description:

Owner/Operator: US Air Force - Bradley Field ANG - 103rd Airlift Wing Location: East Granby, CT Tank Identification: 2 Diameter: 32.75 feet Shell Height: 21.00 feet Capacity: 132,322 Gallons Configuration: Vertical Foundation: Concrete Ringwall Secondary Containment: Concrete Dike Year Installed: 1993 Age: 24 years Construction Code: API-650 8th Edition Appendix H Manufacturer Name: Witherup Fabrication & Erection Inc.

3.3 Service Description:

Service: Jet A Specific Gravity: 0.84 Operating Limits:

Minimum Metal Temperature: Ambient Maximum Metal Temperature: 200 ˚F Minimum Pressure: Atmospheric (no vacuum) Maximum Pressure: Product Seismic Zone: 2A Current Fill Height: 17.00 feet Max Fill Height: 17.00 feet

3.4 Part Description:

Bottom Material: Carbon Steel Specification: Unknown Design: Cone-Down

Shell Material: Carbon Steel Specification: A36 Modified Design: Cylindrical 1st course 0.250” thk.

2nd course 0.250” thk.

3rd course 0.250” thk.

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 7

Roof Material: Carbon Steel Specification: Unknown Design: Cone-Up

Floating Roof Material: Aluminum Specification: Alloy 3003 H14 (Assumed) Design: Flat Honeycomb-Single Pan

3.5 Joint Type Description:

Bottom Plate-to-Plate: Lap-Welded Shell Plate-to-Plate: Butt-Welded Floating Roof Plate-to-Plate: Bolted (Channel members bonded to the panel edge) Fixed Roof Plate-to-Plate: Lap-Welded Bottom-to-Shell: Fillet-Welded Shell-to-Fixed Roof: Fillet-Welded Shell-to-Floating Roof: Double-Wiper Seals

3.6 Inspection Description:

Inspection Type: API-653 Out-of-Service Equipment Used: Ultrasonic Thickness Meter Inspection Date: April 4, 2017 Inspector(s): Gary G. Boley, Christopher M. Bailey, Larry T. Veale

3.7 Equipment Description:

Ultrasonic Thickness Meter

Manufacturer: General Electric Model: DMS Go Calibration Methods Used: Zeroing Procedure, Copper Coating Calibration Procedure, and

Two Point Calibration Procedure

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

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 8

4.0 Inspection

4.1 Results:

4.1.1 Secondary Containment: The tank's foundation is located inside of a concrete secondary containment floor with concrete dike walls. The secondary containment is equipped with a drain and is sloped to allow for drainage away from the tank in accordance with NFPA-

30. The secondary containment was visually evaluated during the inspection. Field assessment indicates the secondary containment is of sufficient size to contain a total tank loss and thus satisfies the requirements of API 653. 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 structurally sound. The secondary containment is in satisfactory condition.

4.1.2 Foundation: The tank sits on a concrete ringwall foundation. The foundation was visually evaluated during the inspection. The bottom-to-foundation seal is not installed. Failure to correct this will allow the intrusion of water and other forms of moisture to the tank bottom, accelerating the corrosion process. Shell settlement surveys were performed during the inspection in accordance with Annex B of API Standard 653. Settlement results are listed in

Appendix A. There is no indication of significant settlement. Overall, the foundation is in satisfactory condition and is within original construction tolerances.

4.1.3 Cathodic Protection: The tank is equipped with an impressed current cathodic protection (ICCP) system. The cathodic protection was visually evaluated during the inspection and was found to be in satisfactory condition.

4.1.4 Bottom: The bottom is constructed from carbon steel of unknown specification. The bottom is of cone-down design, lap-welded together and fillet-welded to the shell. Inspected the interior coating for disbonding, adhesion, deterioration, and discoloration. The condition of the liner is satisfactory. The bottom is equipped with a 24-inch sump. A visual inspection was conducted over the entire bottom, including the bottom welds and the bottom-to-shell weld.

Evaluated the attachments and piping supports. The evaluation showed no corrosion on the bottom, bottom-welds, or the bottom-to-shell weld. Performed a magnetic flux leakage (MFL) evaluation of the tank bottom to determine the condition of the underside. Measured the general thickness throughout the tank bottom utilizing an ultrasonic thickness tester.

4.1.5 Shell: The shell is constructed of carbon steel of modified A36 type design. Evaluated the shell for plumbness, roundness, peaking, and banding; all of which were found to be within the allowable tolerances of the API Standard. The shell is of cylindrical design, butt-welded together, consisting of three (3) courses. Visually inspected the interior and exterior of the shell.

Inspected the coating for disbonding, adhesion, deterioration, and discoloration. The shell was evaluated for remaining metal thickness utilizing ultrasonic technology. Thickness measurements are listed in the Engineering Calculations section in Appendix A. A service life evaluation shows the shell with greater than 30 years of remaining life under current conditions. The engineering calculations, as per API Standard 653, for the service life evaluation are shown in Appendix A under “Service Life Evaluation.” The tank shell is in satisfactory mechanical condition.

4.1.6 Appurtenances: Inspected and evaluated each tank nozzle in accordance with API

Standard 650 and 653. Identified the type and use of each shell nozzle. Measured the nozzle neck thickness on all accessible shell nozzles. Evaluated all nozzles and reinforcement pads for leaks and corrosion, with no discrepancies present. The tank has means of grounding via four ground straps. The secondary containment is not sealed around the ground strap. Evaluated the Shand &

Jurs (Model # 92021-31050200) mechanical tape gauge and its operation. The tank is equipped

INTERSPEC, LLC-PROPRIETARY INFORMATION-FOR OFFICIAL USE ONLY 9

with a leak detection inspection port. Inspected the spiral stairway. Inspected the high level alarm and cutout system. Evaluated the handrails, platforms, and frames. Their condition was found to be satisfactory. There are no mounting plates installed under the diffuser support legs. The reinforcing pads installed under the low suction line are improperly spaced.

4.1.7 Fixed and Floating Roof: The roof is constructed of carbon steel of unknown specification. The roof is of cone-up design, lap-welded together, consisting of fourteen (14) plates which are fillet-welded to the shell rim angle. Evaluated the exterior coating. Evaluated the roof nozzles. Inspected the vents.

The floating roof was visually evaluated during the inspection. Evaluated the operation of the sampling system and the floating roof and measured the floating roof annular…