Attachment K - FAC 580 Inspectoin Report 2019.pdf

US Army Corps of Engineers Omaha District

API 653 In-Service (Visual) Inspection Report

Offutt AFB, Nebraska Tank 13 (Facility 580)

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

(USACE POL-MCX)

12/5/2019

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION DATE

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

B. TANK INSPECTION COMMENTS

1. Secondary Containment

2. Tank Construction

3. Tank Foundation

4. Tank Bottom

5. Tank Shell

6. Tank Floating Roof

7. Tank Fixed Roof

8. Tank Appurtenances

9. Tank Piping System

10. Fire Protection System

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

APPENDIX A: ENGINEERING CALCULATIONS

APPENDIX B: ENGINEERING DRAWINGS

APPENDIX C: ENGINEERING DATA

APPENDIX D: API STANDARD 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX E: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

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

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

GENERAL SUMMARY

Summary of Inspection

An API Standard 653 In-Service (Visual) inspection of Tank 13 (Facility 580) at Offutt AFB, Nebraska was completed on December 5, 2019.

Significant Findings (overview):

Mandatory:

1. None.

Short Term:

1. The 1-inch plug on the issue line is weeping fuel.

2. The tank bottom (chime) to concrete ringwall has a flexible urethane sealant that has several areas of sealant that cracked, deteriorated, and lost seal from the concrete.

3. The weld spacing between the reinforcement weld of the 6-inch sump drain and shell-to-bottom weld does not meet the minimum weld spacing requirements.

4. The weld spacing between the reinforcement weld of the 6-inch sump drain and water draw-off line nozzle weld does not meet the minimum weld spacing requirements.

5. The weld spacing between the reinforcement weld of the 6-inch receipt line and shell-to-bottom weld does not meet the minimum weld spacing requirements.

6. The weld spacing between the reinforcement weld of the 6-inch receipt line and adjacent plugged welded coupling does not meet the minimum weld spacing requirements.

7. The weld spacing between the reinforcement weld of the 8-inch issue line and shell-to-bottom weld does not meet the minimum weld spacing requirements.

8. The weld spacing between the reinforcement weld of the 8-inch issue line and adjacent plugged welded coupling does not meet the minimum weld spacing requirements.

9. The weld spacing between the reinforcement weld of the both 36-inch manholes and shell-to-bottom weld does not meet the minimum weld spacing requirements.

10. The receipt line secondary containment floor penetration sealant has failed.

11. The issue line secondary containment floor penetration sealant has failed.

12. The first step of the circumferential stairway does not match the rise to run of the stairway (too high).

13. The clearance on the circumferential stairway is inadequate at the high level control assemblies and at the wind girder.

Long Term:

1. The concrete walkway around the tank has cracks.

2. The conduit and ground risers have failed sealant between the components and concrete walkway around the tank that has cracked, deteriorated, and lost seal from the concrete.

3. Nearly 100% of the expansion joint sealant of the concrete walkway around the tank has cracked, deteriorated, and lost seal from the concrete. Nearly 100% of the expansion joints that were cut into the concrete have cracked, deteriorated, and lost seal from the concrete.

4. The concrete ringwall to concrete walkway around the tank sealant has cracked, deteriorated, and lost seal from the concrete.

5. One concrete slab of the walkway around the tank has deteriorated.

6. The four (4) ground straps are bolted to the shell and are not exothermically welded to a ground lug with support pad.

7. The product saver tank is not grounded and does not have a housekeeping pad.

8. The water draw-off system includes an external ¾-inch carbon steel threaded piping from a threaded 2-inch coupling on the shell with a 1-inch ball valve and does not have a weld neck flange nozzle penetrating the shell. The water draw line does not have a 2-inch double-block and bleed valve.

The water draw-off piping is not welded stainless steel piping with flanged fittings.

9. The tank is not equipped with a 4-inch low suction line. Note: The tank has a 6-inch sump drain line extending to the sump with a 2-inch hose connection at the tank nozzle but is not tied into the issue line to serve as a low suction line. This nozzle is approximately 50 LF from the issue line.

10. The receipt line does not have a thermal relief system.

11. The thermal relief system for the issue line consists of 1-inch threaded carbon steel piping with two threaded couplings on the shell and piping and non-locking ball valves. The thermal relief system piping is not welded stainless steel piping with flanged fittings and test TEE. Additionally, the thermal relief valve is horizontally mounted in lieu of vertically mounted.

12. The issue line has a field-fitted stub connection in lieu of a standard butt-welded TEE for a 6-inch double-block and bleed valve with a capped hose connection.

13. Both 32-inch manholes have davit arms but are not 36-inch.

14. The mechanical tape level gauge is not readable and failed the bump check.

15. The low level alarm assembly consists of 1-inch welded carbon steel piping and fittings to the flanged lockable ball valve. 1-inch threaded carbon lines extend from the ball valve to the float chamber. The nozzle flanges are not perpendicular to tank shell (pipe elbows before the flange). The components between the tank nozzles are not stainless steel.

16. The high level alarm and high level shut-off assemblies consists of 1-inch threaded carbon steel lines with two threaded couplings on the shell and non-locking ball valves. Additionally, the configuration does not have 1-inch line extending to the product saver tank to allow routine testing.

17. The spiral stairway treads are welded directly to the shell and should have reinforcement pads installed.

18. The manual tape level gauge supports are welded directly to the shell and do not have support pads.

19. The high level shut-off control tubing supports are welded directly to the shell and do not have support pads.

20. The fire line supports are welded directly to the shell and do not have support pads.

21. The tank has four (4) 1-inch threaded plugs in the first shell course (two near low level alarm assembly and two near receipt line). Threaded fittings may leak or weep over time.

22. The shell exterior has several areas coating failure and corrosion near the high level alarm assembly.

The shell has rust streaking from the geodesic dome roof to the bottom in a few areas.

23. The tank does not have a 36-inch upper 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.

24. The fire line is anchored on the pipe supports and do not allow adequate thermal movement.

25. The wind girder does not have any drain holes for drainage. The wind girder is covered by the extension of the geodesic dome; however, a portion of the wind girder is exposed. This may be causing the rust streaking on the shell.

26. The latch on the access hatch on the geodesic dome roof is broken and may open during high winds.

27. The sample gauge well does not have a dedicated sample hatch with a floating seal retriever. The sample gauge is approximately 3 feet from the top platform and is dangerous to access. Access requires stepping onto the geodesic dome. It is apparent the sampling and gauging is accomplished from the

ENRAF access cover based on the presence of paste marking residue inside the cover. Sampling and gauging from the ENRAF access cover pose risk of damaging the system.

28. The ENRAF and VITO systems share a common 8-inch aluminum stilling well that is not slotted and is well away from the center sump. The ATG water probe should be located as close to the center of the tank as possible in a separate stilling well.

29. The floating roof has foam log foam filled coated-fabric seals instead of flexible wiper squeegee seals made of closed cell cast urethane.

30. The tank does not have a facility ID label affixed to the tank.

INSPECTION DATE

API In-Service (Visual) Inspection Date: December 5, 2019 Inspector(s): Wayne K. Bailey

API 653 Inspector No. 1331

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: February 2016 API In-Service (Visual) Inspection Date: February 2016 API In-Service (Ultrasonic) Inspection Date: February 2016

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

API Out-of-Service (Internal) Inspection Date:

UFC-3-460-03 (Internal) Inspection Date:

API In-Service (Visual) Inspection Date:

API In-Service (Ultrasonic) Inspection Date:

February 2046 February 2026 December 2024 February 2031

Wayne K. Bailey, API-653 #1331

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner US Air Force Location Offutt AFB Facility Number 580 Tank Number 13 State / Country Nebraska, United States City Omaha Inspection Date December 5, 2019 Tank Manufacturer American Steel & Iron Design Standard API Standard 650 Date of Construction 1983 Tank Contents Jet A Tank Serial Number 83-189 Tank Diameter 93’ Shell Height 48’ Product Height 37’ 7” Tank Capacity 55,000 barrels (2,310,000 gallons) Foundation Concrete Ringwall

Construction

Bottom Lap-Welded Shell Butt-Welded (Cylindrical) Floating Roof Full Contact Honeycomb Fixed Roof Bolted

Material

Bottom Carbon Steel, Unknown Shell Carbon Steel, Unknown Floating Roof Aluminum Fixed Roof Aluminum

Cathodic Protection Impressed Current Interior Coating System Thin Film Epoxy/Polyurethane Exterior Coating System Thin Film Epoxy/Polyurethane Level Gauging VAREC MTG, ENRAF ATG, and VITO Water & Temp Probe Overfill Protection Mechanical Automatic Shut-Off

Piping

Receipt 8" Carbon Steel Issue 10" Carbon Steel Low Suction NA None Water Draw-Off 1" Carbon Steel

Level Alarms & Controls

Description ENFAR ATG Independent High-High Level Alarm: 40’ 00-0/16” Unknown High-Level Alarm: 39’ 08-07/16” Unknown Low-Level Alarm: 5’ 08-00/16” Unknown Low-Low Level Alarm: 1’ 11-00/16” Unknown High-Level Control Shut-Off: Unknown

Type of Internal Floating Roof Aluminum Full Contact Honeycomb

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.

An API Standard 653 In-Service (Visual) inspection was performed for Tank 13 (Facility 580).

2. Site Information On December 5, 2019 Argus Consulting and our sub-consultant (InterSpec, LLC) performed an API 653 In-Service (Visual) inspection of Tank 13 (Facility 580), located at Offutt AFB, Nebraska.

B. TANK INSPECTION COMMENTS

1. Secondary Containment 40 CFR 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.” 40 CFR 112.8(c)(2) and 40 CFR 112.12(c)(2) state that diked areas must be “sufficiently impervious to contain oil.” The purpose of the secondary containment requirement is to prevent discharges, as described in 40 CFR 112.1(b); therefore, effective secondary containment methods must be able to contain oil until the oil is cleaned up. The secondary containment area consists of rock covered HDPE liner floor and concrete vertical walls. An informal containment evaluation was conducted. Based on visual observation, the containment does appear to be of sufficient size to contain a total tank loss per UFC 3-460- 01 Section 8-14.2.1, “The containment area needs to have sufficient capacity to contain the tank contents plus one foot of freeboard. If the containment has the capacity to contain the tank contents plus one foot of freeboard, the containment area is sufficient.” Based on visual observation, the secondary containment area appears to be properly graded to drain water away from the tank in accordance with NFPA 30. The containment drain is in satisfactory condition.

2. Tank Construction Tank 13 (Facility 580) is a nominal 55,000 barrel, 93’ diameter by 48’ tall, Jet A, aboveground vertical storage tank. The original construction nameplate is affixed to the tank.

3. Tank Foundation The tank rests on top of a concrete ringwall. The tank bottom is equipped with secondary containment liner underneath and a bottom leak detection telltale drain. The tank bottom has an impressed current cathodic protection system. The cathodic protection system was not energized. The cathodic protection system has been deenergized for nearly a year now due to flooding last year. The sealant between the tank bottom and concrete ringwall is not in satisfactory condition. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. The tank bottom-to-pad sealant was inspected; it is not in satisfactory condition. A shell settlement survey was performed during the inspection in accordance with Appendix B of API Standard

653. Settlement results are listed in Appendix A.

4. Tank Bottom Not evaluated during this inspection.

5. Tank Shell The shell is constructed of unknown grade of carbon steel material. The shell is a cylindrical design, butt-welded together, consisting of five courses. The shell (interior and exterior) has a thin film epoxy coating system. The coating was inspected for disbonding, adhesion, deterioration, and discoloration; it is in satisfactory condition. Based on visual observation, roundness, plumbness, peaking, and banding of the shell appear to be within the allowable tolerances of API Standard 653. Based on visual observation, the tank is stable and does not appear to be in danger of overturning or buckling due to high winds or seismic conditions.

6. Tank Floating Roof The tank is equipped with an aluminum internal floating roof. The floating roof is of aluminum honeycomb construction.

7. Tank Fixed Roof The fixed roof is a geodesic dome roof.

8. Tank Appurtenances

a. Water Draw-Off System

1) Water Draw-Off Line: The water draw-off system includes an external 3/4-inch carbon steel threaded piping from a threaded 2-inch coupling on the shell with a 1-inch ball valve and does not have a weld neck flange nozzle penetrating the shell.

The water draw line does not have a 2-inch double-block and bleed valve.

2) Product Saver Tank: The product saver tank (PST) is constructed of stainless steel.

The PST is not grounded. The PST does not have any piping to the high level control assemblies for annual testing.

b. Low Suction Line The tank is not equipped with a low suction line. The tank has a 6-inch sump drain line extending to the sump with a 2-inch hose connection at the tank nozzle but is not tied into the issue line to serve as a low suction line.

c. Issue Line The 10-inch issue line is carbon steel. The 1-inch plug on the issue line is weeping fuel.

The line is protected from overpressure with a thermal relief system. The thermal relief system for the issue line consists of 1-inch threaded carbon steel piping with two threaded couplings on the shell and piping and non-locking ball valves. The thermal relief system piping is not welded stainless steel piping with flanged fittings and test TEE. Additionally, the thermal relief valve is horizontally mounted in lieu of vertically mounted. 12. The issue line has a field-fitted stub connection in lieu of a standard butt-welded TEE for a 6-inch double-block and bleed valve with a capped hose connection.

d. Receipt Line The 8-inch receipt line is carbon steel. The receipt line does not have a thermal relief system.

e. Automatic Tank Gauging (Fuel Level) The tank is equipped with an ENRAF system for electronic fuel level gauging. The ENRAF and VITO systems share a common 8-inch aluminum stilling well that is not slotted.

f. Automatic Tank Gauging (Water Level) The tank is equipped with an ENRAF VITO system for electronic water level gauging.

The ENRAF and VITO systems share a common 8-inch aluminum stilling well that is not slotted. This stilling well is located near the sump, and the probe sensor rests adjacent to the sump.

g. Mechanical Tank Gauging The tank is equipped with a VAREC mechanical tape level gauge for mechanical fuel level gauging. The system is in functional condition.

h. Tank Sampling\Manual Gauging The sample gauge well does not have a dedicated sample hatch with a floating seal retriever. The sample gauge is approximately 3 feet from the top platform and is dangerous to access. Access requires stepping onto the geodesic dome. It is apparent the sampling and gauging is accomplished from the ENRAF access cover based on the presence of paste marking residue inside the cover. Sampling and gauging from the ENRAF access cover pose risk of damaging the system.

i. Level Alarms\High Level Shut-Off The ENRAF system provides low, low-low, high, and high-high level alarms. The tank is equipped with independent low, low-low, high and high-high level alarms.

The independent high level alarm assembly and high level shut-off assembly are accessible from a platform on the circumferential stairway. The high level alarm and high level shut-off assemblies consists of 1-inch threaded carbon steel lines with two threaded couplings on the shell and non-locking ball valves.

j. Ladder and Platforms The geodesic dome roof is accessible by a circumferential stairway mounted on the shell of the tank. The circumferential stairway does not have a platform at the high level alarm assemblies. The clearance on the circumferential stairway is inadequate at the high level control assemblies and at the wind girder. The floating roof is accessible by in internal ladder.

k. Grounding The tank has four (4) grounding straps around the circumference of the tank. The grounding cables are bolted to the shell and are not exothermically welded to a ground lug with support pad.

l. Anchoring The tank does not have any anchors around the circumference of the tank.

9. Tank Piping System Fuel is received from truck and pipeline storage and issued to the hydrant tanks.

10. Fire Protection System The fire department provides fire protection. The tank has three fire hydrants along the access road in the tank farm.

C. FINDINGS AND RECOMMENDATIONS

The following information identifies the significant findings found during the tank inspection:

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.

a. None

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

a. Plug Weep on Issue Line OBSERVATION: The 1-inch plug on the issue line is weeping fuel between the valve and threaded coupling.

CODE REFERENCE: Good Engineering Practice RECOMMENDATION: Repair the weeping plug on the issue line.

b. Sump Drain Reinforcement Pad to Bottom Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 6-inch sump drain and shell-to-bottom weld does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 1-1/2 inches, 10 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1 RECOMMENDATION: Magnetic particle (MT) examination is required by API Standard 653 Section 4.3.9.1 on the affected welds.

c. Sump Drain Reinforcement Pad to Water Draw-Off Nozzle Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 6-inch sump drain and water draw-off line nozzle weld does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 1 inch, 6 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

d. Receipt Line Reinforcement Pad to Bottom Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 6-inch receipt line and shell-to-bottom weld does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 3 inches, 10 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

e. Receipt Line Reinforcement Pad to Plugged Coupling Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 6-inch receipt line and adjacent plugged welded coupling does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 1 inch, 6 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

f. Issue Line Reinforcement Pad to Bottom Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 8-inch issue line and shell-to-bottom weld does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 1 inch, 10 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

g. Issue Line Reinforcement Pad to Thermal Relief Coupling Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the 8-inch issue line and adjacent thermal relief coupling does not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured 1 inch, 6 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

h. Manhole Reinforcement Pads to Bottom Weld Spacing OBSERVATION: The weld spacing between the reinforcement weld of the manholes and shell-to-bottom weld do not meet the minimum weld spacing requirements of API Standard 650 Section 5.7 and Figure 5.6 (weld spacing measured ±3 inches, 10 inches is required). The affected welds are acceptable for continued service if the welds are examined by the magnetic particle method and have no rejectable defects or indications.

CODE REFERENCE: API Standard 650 Section 5.7 and Figure 5.6 and API Standard 653 Section 4.3.9.1

i. Bottom-To-Ringwall Sealant OBSERVATION: The sealant between the tank bottom and concrete pad has failed around most of the circumference.

CODE REFERENCE: 40 CFR 112.7(c); 40 CFR 112.8(c)(2), 40 CFR 112.12(c)(2), 40 CFR 112.1(b) and ASTM C 920 RECOMMENDATION: Replace the failed sealant between the concrete ringwall and concrete walkway around the tank with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

j. Receipt Line to Containment Floor Sealant OBSERVATION: The receipt line secondary containment floor penetration sealant has failed.

CODE REFERENCE: 40 CFR 112.7(c); 40 CFR 112.8(c)(2), 40 CFR 112.12(c)(2), 40 CFR 112.1(b) and ASTM C 920 RECOMMENDATION: Replace the failed sealant between the concrete walkway and receipt line with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

k. Issue Line to Containment Floor Sealant OBSERVATION: The issue line secondary containment floor penetration sealant has failed.

CODE REFERENCE: 40 CFR 112.7(c); 40 CFR 112.8(c)(2), 40 CFR 112.12(c)(2), 40 CFR 112.1(b) and ASTM C 920 RECOMMENDATION: Replace the failed sealant between the concrete walkway and issue line with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

l. Circumferential Stairway Base OBSERVATION: The first step of the circumferential stairway does not match the rise to run of the stairway (too high).

CODE REFERENCE: API Standard 650 Table 5.18 and OSHA 29 CFR 1910.25 RECOMMENDATION: Add a concrete step at the base of the circumferential stairway for a uniform rise and run.

m. Circumferential Stairway Clearance OBSERVATION: The clearance on the circumferential stairway is inadequate at the high level control assemblies (measured 21 inches) and at the wind girder (measured 17-1/2 inches).

CODE REFERENCE: OSHA 29 CFR 1910.25

RECOMMENDATION: Replace the circumferential steps with wider steps to allow adequate clearance around the high level control assemblies and wind girder.

n. Bottom Leak Detection Telltale Drain OBSERVATION: A bottom leak detection telltale drain is not fitted with a valve, cap, or plug to prevent the ingress of water from external sources in accordance with API Standard 650 Section I.5.7. The concrete adjacent to the drain has rust staining.

CODE REFERENCE: API Standard 650 Section I.5.7 RECOMMENDATION: Install a valve, cap, or plug for the exposed bottom leak detection telltale drain in accordance with API Standard 650 Section I.5.7.

3. RECOMMENDED REPAIRS TO FULLY COMPLY WITH UFC 3-460-01, AW 78-24-27 Standards or 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. Cracks in Concrete Walkway OBSERVATION: The concrete walkway around the tank has cracks with sealant that has cracked, deteriorated, and lost seal from the concrete.

RECOMMENDATION: Repair all cracks in the concrete walkway around the tank by grinding in a V-shape pattern with at least ¼-inch width at the surface and a depth of at least ¼-inch and sealing with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

Note: Repair is necessary to prevent deterioration of the concrete walkway.

b. Ground Riser Sealant OBSERVATION: The conduit and ground risers have failed sealant between the components and concrete walkway around the tank that has cracked, deteriorated, and lost seal from the concrete.

CODE REFERENCE: Good Engineering Practice RECOMMENDATION: Replace the failed sealant between the conduit and ground risers and the concrete walkway around the tank with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant.

c. Walkway Expansion Joint Sealant OBSERVATION: Nearly 100% of the expansion joint sealant of the concrete walkway around the tank has cracked, deteriorated, and lost seal from the concrete (120 LF). Nearly 100% of the expansion joints that were cut into the concrete have cracked, deteriorated, and lost seal from the concrete.

CODE REFERENCE: UFGS 07 92 00 and Good Engineering Practice RECOMMENDATION: Remove damaged joint sealant and install new backer rods and sealant within the concrete walkway around the tank. The sealant shall be adequate to accommodate joint compression equal to 50 percent of the width of the joint. The backer rod shall be compressible rod stock of polyethylene foam, polyurethane foam, butyl rubber foam, or other flexible, non-absorptive material as recommended by the sealant manufacturer. Sealant shall conform to UFGS 07 92 00 Joint Sealant. Note:

Repair is necessary to prevent deterioration of the concrete walkway.

d. Ringwall to Walkway Expansion Joint Sealant OBSERVATION: The concrete ringwall to concrete walkway around the tank sealant has cracked, deteriorated, and lost seal from the concrete.

CODE REFERENCE: Good Engineering Practice RECOMMENDATION: Replace the failed sealant between the concrete ringwall and concrete walkway around the tank with flexible urethane (e.g. Sikaflex 1c) or a similar approved sealant. Note: Repair is necessary to prevent deterioration of the concrete walkway.

e. Concrete Walkway Slab OBSERVATION: One concrete slab of the walkway around the tank has deteriorated. The walkway has several spalled areas.

CODE REFERENCE: UFGS 32 13 15.20 and Good Engineering Practice RECOMMENDATION: Replace the deteriorated concrete slab of the walkway around the tank and the spalled areas in accordance with UFGS 32 13 15.20, Concrete Pavement for Containment Dikes. Note: Repair is necessary to prevent deterioration of the concrete walkway.

f. Tank Grounding OBSERVATION: The eight (8) ground straps are bolted to the shell and are not exothermically welded to a ground lug with support pad. The grounding cables are braided and cannot be properly sealed at the secondary containment floor penetration. The grounding cable should be attached to a grounding rod to penetrate secondary containment floor.

CODE REFERENCE: AW 78-24-27 Drawing ED.02 Details 1 and 2 and API Standard 650 Section 5.8.11.3 RECOMMENDATION: Reconfigure the grounding cables with exothermic weld connections to ground lugs with support pads on the shell. Reconfigure the grounding cables affixed to a grounding rod for proper sealing of the penetration through the secondary containment floor.

g. Product Saver Tank Grounding and Housekeeping Pad OBSERVATION: The product saver tank is not grounded and does not have a housekeeping pad.

CODE REFERENCE: AW 78-24-27 Drawing D.13 Detail 5 RECOMMENDATION: Install a ground to the product saver tank and install a house keeping pad in accordance with AW 78-24-27 Drawing D.13 Detail 5.

h. Water Draw-Off Configuration OBSERVATION: The water draw-off system includes an external ¾-inch carbon steel threaded piping from a threaded 2-inch coupling on the shell with a 1-inch ball valve and does not have a weld neck flange nozzle penetrating the shell. The water draw line does not have a 2-inch double-block and bleed valve. The water draw-off piping is not welded stainless steel piping with flanged fittings.

CODE REFERENCE: UFC 3-460-01 Section 3-6 (i) and AW 78-24-27 Drawing D.13 Detail 5 RECOMMENDATION: Replace the ¾-inch shell nozzle with a 2-inch shell nozzle and reconfigure the carbon steel piping with welded and flanged stainless steel piping in accordance with AW 78-24-27 Drawing D.13 Detail 5.

i. Low Suction Line Configuration OBSERVATION: The tank is not equipped with a 4-inch low suction line. Note: The tank has a 6-inch sump drain line with a 2-inch hose connection at the tank nozzle but is not tied into the issue line to serve as a low suction line. This nozzle is approximately 50 LF from the issue line and has inadequate weld spacing between the water draw-off and shell-to-bottom welds.

CODE REFERENCE: API Standard 653 Section 9.2, UFC 3-460-01 Table 8-1 Item (z), and AW 78- 24-27 Drawing D.07 Detail 5 RECOMMENDATION: Remove the drain line and shell nozzle and replace with a butt-welded tombstone insert in accordance with API Standard 653 Section 9.2. Install a 4-inch low suction line close to the issue line in accordance with AW 78-24-27 Drawing D.07 Detail 5.

j. Thermal Relief Line Configuration for Receipt Line OBSERVATION: The receipt line does not have a thermal relief system.

CODE REFERENCE: UFC 3-460-01 Section 9-3.5.1 and AW 78-24-27 Drawing D.10 Detail 4 RECOMMENDATION: Install a thermal relief line on the receipt line in accordance with AW 78- 24-27 Drawing D.10 Detail 4.

k. Thermal Relief Line Configuration for Issue Line OBSERVATION: The thermal relief system for the issue line consists of 1-inch threaded carbon steel piping with two threaded couplings on the shell and piping and non-locking ball valves.

The thermal relief system piping is not welded stainless steel piping with flanged fittings and test TEE. Additionally, the thermal relief valve is horizontally mounted in lieu of vertically mounted.

CODE REFERENCE: UFC 3-460-01 Section 9-3.5.1 and AW 78-24-27 Drawing D.10 Detail 4 RECOMMENDATION: Replace the thermal relief line on the issue line in accordance with AW 78-24-27 Drawing D.10 Detail 4.

l. Issue Line TEE Connection OBSERVATION: The issue line has a field-fitted stub connection in lieu of a standard butt-welded TEE for a 6-inch double-block and bleed valve with a capped hose connection.

CODE REFERENCE: UFC 3-460-01 Section 9-8 Item (h) RECOMMENDATION: Replace the field-fitted stub connection with a butt-welded TEE that can be radiographed in accordance with UFC 3-460-01 Section 9-8 Item (h).

m. Manhole Configuration OBSERVATION: Both 32-inch manhole covers have only one handle (2 handles are required by API). The manholes are not 36-inch.

CODE REFERENCE: API Standard 650 Section 5.8.3.5 and AW 78-24-27 Drawing D.10 Detail 3 RECOMMENDATION: Replace the manholes with 36-inch manholes in accordance with AW 78- 24-27 Drawing D.10 Detail 3 or, at a minimum, install an additional handle in accordance with AW 78-24-27 Drawing D.10 Detail 3. Note: The manhole reinforcement pad to shell-to-bottom weld spacing is inadequate.

n. Mechanical Tape Level Gauge OBSERVATION: The mechanical tape level gauge is not readable and failed the bump check.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (q) and AW 78-24-27 Drawing D.07 Detail 1 RECOMMENDATION: Replace the VAREC mechanical tape level gauge.

o. Independent Low Level Alarm Assembly Configuration OBSERVATION: The low level alarm assembly consists of 1-inch welded carbon steel piping and fittings to the flanged lockable ball valve. 1-inch threaded carbon lines extend from the ball valve to the float chamber. The nozzle flanges are not perpendicular the to tank shell (pipe elbows before the flange). The components between the tank nozzles are not stainless steel.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (l) and AW 78-24-27 Drawing D.12 Detail 1 RECOMMENDATION: Reconfigure the low level alarm and low-low level assembly in accordance with AW 78-24-27 Drawing D.12 Detail 1.

p. High Level Alarm and High Level Shut-Off Assembly Configuration OBSERVATION: The high level alarm and high level shut-off assemblies consists of 1-inch threaded carbon steel lines with two threaded couplings on the shell and non-locking ball valves. Additionally, the configuration does not have 1-inch line extending to the product saver tank to allow routine testing.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (l) and AW 78-24-27 Drawing D.12 Details 2 and 3 RECOMMENDATION: Reconfigure the high level alarm and high level shut-off assemblies in accordance with AW 78-24-27 Drawing D.12 Details 2 and 3.

q. Circumferential Stairway Configuration OBSERVATION: The spiral stairway treads are welded directly to the shell and do not have reinforcement pads installed.

CODE REFERENCE: AW 78-24-27 Drawing D.11 Details 1 - 4 RECOMMENDATION: Replace the circumferential stairway in accordance with AW 78-24-27 Drawing D.11 Details 1 - 4.

r. Mechanical Tape Level Gauge Shell Supports OBSERVATION: The mechanical tape level gauge piping supports are welded directly to the shell without reinforcement pads.

CODE REFERENCE: AW 78-24-27 Drawing D.07 Detail 1 RECOMMENDATION: Install shell support pads for the mechanical tape level gauge in accordance with AW 78-24-27 Drawing D.07 Detail 1 and Drawing D.10 Detail 5.

s. High Level Alarm Conduit and High Level Shut-Off Tubing Shell Supports OBSERVATION: The high level alarm conduit and high level shut-off tubing supports are welded directly to the shell without reinforcement pads.

CODE REFERENCE: AW 78-24-27 Drawing D.10 Detail 5 RECOMMENDATION: Install shell support pads for the high level alarm conduit and high level shut-off tubing supports in accordance with AW 78-24-27 Drawing D.10 Detail 5.

t. Fire Line Shell Supports OBSERVATION: The fire line supports are welded directly to the shell and do not have support pads.

RECOMMENDATION: Install shell support pads for the fire line supports.

u. Threaded Plugs in Shell First Course OBSERVATION: The tank has four (4) 1-inch threaded plugs in the first shell course (two near low level alarm assembly and two near receipt line). Threaded fittings may leak or weep overtime.

CODE REFERENCE: API Standard 653 Section 9.3 RECOMMENDATION: Remove the threaded plugs and install a lap-welded patch plate in accordance with API Standard 653 Section 9.3.

v. Shell Exterior Coating OBSERVATION: The shell exterior has several areas coating failure and corrosion near the high level alarm assembly. The shell has rust streaking from the roof to the bottom in a few areas.

CODE REFERENCE: UFGS 09 97 3.1.2.1

RECOMMENDATION: Repair the shell exterior coating failure and corrosion near the high level alarm assembly in accordance with UFGS 09 97 3.1.2.1.

w. Upper Manhole OBSERVATION: The tank does not have a 36-inch upper 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.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (c), AW 78-24-27 Drawing D.10 Details 3 and 6 and Drawing D.11 Details 1 and 2 RECOMMENDATION: Install a 36-inch upper manhole in accordance with AW 78-24-27 Drawing D.10 Details 3 and 6 with a platform on the circumferential stairway in accordance with AW 78-24-27 Drawing D.11 Details 1 and 2.

x. Fire Line Pipe Supports in Secondary Containment OBSERVATION: The fire line is anchored on the pipe supports and does not allow adequate thermal movement.

CODE REFERENCE: AW 78-24-27 Drawings CD.12 and CD.13 RECOMMENDATION: Replace the fire line pipe supports inside the secondary containment in accordance with AW 78-24-27 Drawings CD.12 and CD.13.

y. Wind Girder Drainage OBSERVATION: The wind girder does not have any drain holes for proper drainage of accumulated water in accordance with API Standard 650 Section 7.6.3.2 Item 7. The wind girder is covered by the extension of the geodesic dome; however, a portion of the wind girder is exposed. This may be causing the rust streaking on the shell.

CODE REFERENCE: API Standard 650 Section 7.6.3.2 Item 7 RECOMMENDATION: Add drainage means for the wind girder to prevent water accumulation.

z. Internal Ladder Access Hatch OBSERVATION: The latch on the access hatch for the internal ladder on the geodesic dome roof is broken and may open during high winds.

CODE REFERENCE: Good Engineering Practice RECOMMENDATION: Replace the latching mechanism on the access hatch for the internal ladder on the geodesic dome.

aa. Sample Gauge Configuration OBSERVATION: The sample gauge well does not have a dedicated sample hatch with a floating seal retriever. The sample gauge is approximately 3 feet from the top platform and is dangerous to access. Access requires stepping onto the geodesic dome. It is apparent the sampling and gauging is accomplished from the ENRAF access cover based on the presence of paste marking residue inside the cover. Sampling and gauging from the ENRAF access cover pose risk of damaging the system.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (x) and AW 78-24-27 Drawing D.07 Detail 2 RECOMMENDATION: Install a platform to safely access the sample gauge. Install a floating seal retriever on the sample gauge in accordance with AW 78-24-27 Drawing D.07 Detail 2.

bb. VITO Automatic Tank Gauge (Water Level/Temperature) Configuration OBSERVATION: The ENRAF and VITO systems share a common non-slotted 8-inch aluminum stilling well and is well away from the center sump. Entanglement could damage the systems and provide inaccurate measurements. The ATG water probe should be located as close to the center of the tank as possible in a separate stilling well.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Items (v) and (w) and AW 78-24-27 Drawing D.07 Details 3 and 4 RECOMMENDATION: Install the VITO water probe in separate slotted stilling well near the sump in accordance with AW 78-24-27 Drawing D.07 Detail 3. Note: The tank has a geodesic dome roof, and it is not feasible to install the VITO water probe near the center of the tank.

cc. ENRAF Automatic Tank Gauge (Fuel Level) Configuration OBSERVATION: The ENRAF and VITO systems share a common non-slotted 8-inch aluminum stilling well and is well away from the center sump. Entanglement could damage the systems and provide inaccurate measurements.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Items (v) and (w) and AW 78-24-27 Drawing D.07 Detail 4 RECOMMENDATION: Install slots in the current stilling well in accordance with AW 78-24-27 Drawing D.07 Detail 4.

dd. Floating Roof Seals OBSERVATION: The floating roof has foam log foam filled coated-fabric seals instead of flexible wiper squeegee seals made of closed cell cast urethane. Foam filled coated-fabric seals shall not be accepted.

CODE REFERENCE: UFGS 33 56 13.13 Section 2.13.2.7 RECOMMENDATION: Remove the existing foam log periphery seals and install double wiper seals in accordance with UFGS 33 56 13.13 Section 2.13.2.7.

ee. Facility ID Labeling OBSERVATION: The tank does not have a facility ID label affixed to the tank.

CODE REFERENCE: UFC-3-460-01 Section 2-17 RECOMMENDATION: Install a facility label on the tank.

ff. Unused Shell Nozzles in Upper Shell Course OBSERVATION: The tank has several unused shell nozzles and threaded plugs in the upper shell course.

CODE REFERENCE: API Standard 653 Section 9.3 RECOMMENDATION: Remove the unused shell nozzles and threaded plugs in the upper shell course and install lap-welded patch plates in accordance with API Standard 653 Section 9.3.

gg. Concrete Around Issue Line Penetration OBSERVATION: The issue line penetrates near the edge of the concrete walkway. The concrete has cracked. Repairs of the cracked concrete are addressed in previous section.

The concrete most likely will break due to the close proximity to the edge.

CODE REFERENCE: Good Engineering Practice RECOMMENDATION: Install a keyway around the issue line to increase the edge distance of the concrete penetration.

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