J.3_SCT-FAC 8734-FY20-Final.pdf

API-653 In-Service Inspection Scott Air Force Base April 24, 2020 FINAL Tank 34(FACILITY 8734)

US Army Corps of Engineers Omaha District

API 653 In-Service Inspection Report

Scott Air Force Base; St. Clair County, Illinois Facility 8734

Tank 34

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

(USACE POL-MCX)

April 24, 2020

API 653 In-Service Inspection Report Scott AFB, Illinois

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION DATE

STATE REGULATIONS

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

GENERAL TANK INFORMATION

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

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

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 SHELL SERVICE LIFE EVALUATION

A.2 SHELL SETTLEMENT EVALUATION

A.3 ULTRASONIC UT DATA

A.4 SHELL LAYOUT DRAWING

A.5 ROOF LAYOUT DRAWING

A.6 CONTAINMENT LAYOUT DRAWING

A.7 OSHA ACCESS STRUCTURE REPORT

APPENDIX B: 3-D DOCUMENTATION AND ANALYSIS

APPENDIX C: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX D: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

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 visual external inspection, in-service, of Tank 34 (Facility 8734) at Scott AFB, Illinois was completed on April 24, 2020. The tank Inspection was conducted per applicable industry standards (API 653), NFPA 30, and in compliance with 40 CFR 112, UFC 3-460-01, UFC 3-460-03, and any other applicable federal, state, local, service, or host nation requirements. All tank appurtenances that are required are documented along with all required appurtenances that aren’t present. Alarms, automatic tank gauge equipment, and all tank appurtenances were tested or verified to be in operation when present. The secondary containment was also visually inspected and assessed for ability to contain the entire contents of the tank in the event of catastrophic failure. Additionally, the secondary containment was assessed for cracks, settlement, and deterioration.

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

a. No Mandatory Repairs were identified for this tank.

REQUIRED REPAIRS to Fully Comply with API 653, Federal, State, or Local Codes:

a. The concrete secondary containment basin has approximately 42 Linear Feet (LF) of unsealed cracks.

b. The concrete secondary containment berm has approximately 25 LF of minor to moderate cracks on the interior section of the wall.

c. The concrete secondary containment berm has approximately 18 LF of failed sealant on previously repaired cracks on the interior and top section of the wall.

d. The concrete secondary containment berm walkway has approximately 18 LF of minor to moderate cracks on the top section of berm.

e. The concrete secondary containment berm has approximately 75 LF of minor to moderate cracks on the exterior section of the wall.

f. The concrete secondary containment has approximately 33 LF of failed control joint sealant that was previously repaired on the floor and berm wall.

g. The section of the perimeter on the top of the berm is not sealed (approximately 200 LF). The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage.

h. The circumferential stairway has inadequate clearance between the handrail and the high level alarm chamber. The existing clearance between the chamber and handrail is 18.5 inches. 29 CFR

1910.24(d) requires a minimum width of 22 inches.

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

j. The Product Saver Tank (PST) is not grounded.

k. The conduit of the tank side indicator of the ENRAF automatic tank gauge does not have a conduit seal-off.

l. The T-style conduit outlet body cover is loose on the Tank Side Indicator (TSI).

m. There are no seal-offs provided for the tank equipment conduits at the secondary containment exit area. Seal-off is required where the NFPA electrical classification of the area changes, such as where it leaves the secondary containment.

n. There are no seal-offs provided for the ATG conduits. Seal-off is required where the NFPA electrical classification of the area changes, such as where it is mounted on the roof near openings.

o. There are no seal-offs provided for the VITO automatic tank gauge water probe mounted on the roof. Seal-off is required where the NFPA electrical classification of the area changes, such as where it is mounted on the roof near openings.

p. Both the HLA/HHLA and LLA/LLLA conduits are not equipped with conduit seal-offs.

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

r. The tank does not have two scaffold cable supports installed on the fixed roof in accordance with

UFC 3-460-01 and API STD 650.

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

t. The circulation vent/inspection hatch screens are equipped with coarse mesh screen with an insect screen. API 650 and industry standards recommend the use of corrosion-resistant coarse-mesh screens to reduce the possibility of clogging.

u. Two of the stairway treads were welded on or very close to the tank horizontal seam. This does not meet good engineering practice and current API standard.

RECOMMENDED REPAIRS TO Fully Comply with UFC 3-460-01, AW 78-24-27 Standards, or as Part of

Regular Maintenance:

a. The sample gauge well has 2 latches that do not engage to secure the floating seal receiver.

b. The 1-inch water draw-off line has threaded stainless steel piping and does not have a 2-inch double-block and bleed valve at the tank (currently is a 3/4-inch ball valve). The water draw-off line is not flanged at the shell and has a stainless steel to carbon steel threaded coupling on the shell. Dissimilar metal threaded couplings could leak over time.

c. The shell mounted MTG supports do not have mounting plates seal- welded to the shell. Some porosity was noted on accessible sections of the MTG bracket (coating removal required to perform

PT or MT).

d. The shell manhole covers are a hinged type with no davit arm. These types of hinged manhole covers are prone to shear damage of the pins, particularly on hinges without grease fittings.

e. The NFPA diamond placard is faded. The fire hazard (red box) and the reactivity (yellow box) are faded.

f. The flexible conduit to the High Liquid Level Shut-off Valve (HLV) pilot solenoid is resting on the Cla

Val body. Minor abrasion damage was noted.

g. Three conduits at the northeast berm pipe penetration are missing conduit support clamps.

h. Both the receipt and issue lines are equipped with Over Voltage Protection (OVP) devices. The OVP on the issue line was resting on top of the flange at the time of the inspection. The tank is not equipped with a CP system.

i. The manufacturer data plates on the receipt and issue for the thermal relief valves are covered with paint.

j. A section of the stainless steel product piping (ball joints) and flanged appurtenances is coated.

k. The tank Double-Block and Bleed (DBB) valves are not equipped with limit switches.

l. The tank is not equipped with a shell manhole located above the internal floating pan’s high position (see additional notes for this finding).

m. The circulation/inspection hatch does not meet the shape and material listed on the current DoD

Standard AW 078-24-27.

INSPECTION DATE

API In-Service (External) Inspection Date: 24 April 2020

Equipment (s) Used:

Ultrasonic Thickness (A-scan/B-scan) Testing Manufacturer: General Electric Model: DMS Go+ Calibration Methods Used: Zeroing Procedure, Copper Coating Calibration Procedure, and Two Point Calibration Procedure

Tank Settlement Surveying

Manufacturer: Hilti Model: Hilti Rotating laser PR 30-HVS A12 Calibration Methods Used: Main and transverse horizontal axes checks at 20 m < 2 mm

Inspector(s): Benyam Berhane

STATE REGULATIONS

State Regulation for API In-Service Tank Inspections N/A State Regulation for API Out-of-Service Tank Inspections N/A NOTE: If there are no state regulations for tank inspections, then N/A shall reside in-place of the number of years between inspections. If state regulations reside, the recommended future inspection dates shall be based on whichever is more stringent between the API inspector’s calculations and the state regulations.

PREVIOUS INSPECTION DATES

API Out-of-Service (Internal) Inspection Date: 10 June 2015 API In-Service (External) Inspection Date: February 2010 Alteration/Repairs Completed: 1996 = New tank bottom. ¾” nozzles w/ internal piping, 8” nozzle (diffuser), 10” nozzle w/ internal piping, two 8” gauge poles, 24” bottom sump, two 36” manholes.

2011 = Underside of bottom projection welded to the dead shell.

2017 = Internal modification, additional stilling wells added, New independent level alarms and HLV installed, stairway modifications, new pipe crossover staircase inside dike, secondary containment sealant repairs, foundation repair, external low suction pipe upgrades .

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

* 20 yrs. for tanks without Release Prevention Barrier. 30 yrs. for tank with Release Prevention Barrier.

UFC 3-460-03 Indicates Internal (Out-of-Service API 653) inspection every ten (10) years

Benyam Berhane Mechanical Engineer/Sr. Inspector InterSpec, LLC API 653 Certified Inspector No. 28492

Routine In-service Inspections (API 653-6.3.1): Monthly (owner/operator personnel) External (Visual) Inspection (API 653-6.3.2): 24 April 2025 Ultrasonic Thickness Inspection (API 653 -6.3.3): 24 April 2035 Internal Inspection* (API 653 – 6.4): 24 April 2035 (Based on June 2015 OOS Inspection)

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S. Air Force

Location Scott AFB

Facility Number 8734

Tank Number 34

State / Country Illinois/USA

City St. Clair County

Inspection Date April 24, 2020

Tank Manufacturer Graver Tank and Manufacturing Co.

Design Standard API Standard 12C

Date of Construction 1952

Tank Contents Jet Fuel (F-24)

Tank Serial Number 40685

Tank Diameter 35 feet

Shell Height 30 feet

Product Height 24’ 7"

Tank Capacity 4,221 BBL ( 177,301 Gallons)

Foundation Concrete Pad

Construction

Bottom Lap-Welded (Cone-Down)

Shell Butt-Welded (Cylindrical)

Floating Roof Aluminum Honeycomb

Fixed Roof Lap-Welded (Supported Cone)

Material

Bottom Carbon Steel (Unknown Specification)

Shell Carbon Steel (Unknown Specification)

Floating Roof Aluminum

Fixed Roof Carbon Steel (Unknown Specification)

Cathodic Protection None

Interior Coating System N/A (In-service inspection) Assumed Epoxy

Exterior Coating System Epoxy with a polyurethane top

Level Gauging Enraf servo ATG, Vito water probe, and manual gauging in separate aluminum gauge well. Varec mechanical tape level gauge.

Overfill Protection High-liquid level shut-off valve with Independent high and high-high level alarms

Piping Receipt 8” Carbon Steel

Issue 10” Carbon Steel

Low Suction 4” Carbon Steel

Water Draw-Off ¾” Carbon Steel

Level Alarms

High-High Level Alarm: 24' 03-00/16"(Independent) 25' 02-14 /16" (ATG) High Level Alarm: 21' 11-00/16"(Independent) 21' 11-00 /16" (ATG) Low Level Alarm: 3' 09-00/16" (Independent) 3' 09-00 /16" (ATG) Low-Low Level Alarm: 2' 11-00/16" (Independent) 1' 03-07 /16"(ATG)

Type of Internal Floating Roof

Petrex Aluminum 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 visual external inspection, in-service, was performed for Tank 34 (Facility 8734).

2. Site Information

On April 24, 2020 InterSpec, LLC under contract to Argus Consulting Inc. performed a visual external inspection, in-service, of Tank 34 (Facility 8734) located at Scott AFB, Illinois. Scott AFB is the headquarters of the U.S. Air Force Air Mobility Command (AMC). Additionally, Scott AFB is home to the

932nd Airlift Wing (Reserve Unit) and the 126th Air Refueling Wing (Air National Guard Unit). Scott

AFB is located approximately 17 miles east southeast of St. Louis in St. Clair County, Illinois.

Tank 34 (Facility 8734) is used as an aboveground fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 34 (Facility 8734) is a nominal 4,200 BBL (177,301 Gallon), 35‐foot diameter by 29.25‐foot tall, Jet Fuel (F-24), aboveground vertical storage tank. The tank was fabricated by Graver Tank and

Manufacturing, Co. in 1952 to API-12C standard. A new tank bottom was installed in 1996 along with

¾” nozzles w/ internal piping, 8” nozzle (diffuser), 10” nozzle w/ internal piping, two 8” gauge poles, 24” bottom sump, and two 36” manholes. Repair/alternation was performed by Matrix Service. The underside of the second bottom plate projection was seal-welded in 2011. Additional upgrades were completed in 2017, (performed by Dawson), and included internal modification, additional stilling wells added, new independent level alarms and HLV installed, stairway modifications, new pipe crossover staircase inside dike, secondary containment sealant repairs, foundation repair, and external low suction pipe upgrades

2. Tank Foundation

The tank sits on a concrete pad foundation that is elevated approximately 1” inch above the secondary containment floor. The foundation is not equipped with a leak detection (tell‐tale) system that extends through the ringwall. Accessible sections of the foundation were visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. No vegetation or cracks was present. The foundation had a coating system installed in 2017. The bottom plate extension on the original tank bottom (chime) is sealed and is in satisfactory condition. A shell settlement survey was performed in accordance with Annex B of API Standard 653. The foundation has minor settlement.

3. Tank Shell

The tank shell is constructed from carbon steel material of an unknown specification. The shell is of cylindrical design, butt-welded together and consisting of five (5) courses. Visually evaluated the shell for plumbness, roundness, peaking, and banding; all of which were appear to be within the allowable tolerances of the API Standard 653. Visually inspected the exterior of the shell. Inspected the coating for dis-bonding, adhesion, deterioration, and discoloration. The tank shell is equipped with two manholes that are 180 degrees apart and are both sized as a 36" opening. The tank is equipped with shell mounted low-low level alarm, low level alarm, high level alarm, high-high level alarms, as well as a high-level shut-off.

4. Tank Appurtenances

a. Internal Floating Roof

The tank is equipped with a PETREX internal floating roof. The floating roof is of aluminum honeycomb construction. Accessible sections of the primary and secondary double wiper seals along with the roof opening gaskets were inspected for tears and deterioration via inspection hatches (no tank entry performed).

b. Fixed Roof

The fixed roof is a supported cone roof constructed of carbon steel material. The fixed roof has an epoxy coating system on the interior and exterior. The external coating was inspected for disbonding, adhesion, deterioration, and discoloration. The coating is in satisfactory condition. The fixed roof was evaluated for remaining metal thickness using ultrasonic technology. The ultrasonic thickness measurements and ultrasonic thickness locations (TML) are listed in the Fixed Roof Plate Thickness Measurements table in

Appendix A. The roof does not have any scaffold supports.

c. Gauging

The tank’s Enraf (Model #854) ATG and Vito water probe (Model #unknown) are installed through an 8-inch aluminum stilling well using a 10-inch roof nozzle. The transmitter outputs the tank level to a continuous electronic tank monitoring system (FuelsManager

Software) manufactured by Varec. The tank is also equipped with a Model 977 Tank Side

Indicator (TSI) that is mounted at the base of the circumferential stairway. The ATG system was locally shutoff and the computer/software was also shut off at the time of the inspection for maintenance. The tank is equipped with a float and tape type Mechanical

Tape Gauge (MTG) manufactured by Varec (Model 2500). The overall general conditions of the tank gauging systems are satisfactory with some exceptions. The MTG is working correctly but is directly attached to the floating roof and cannot be bump-checked.

d. Level Alarms

The high-high and high level sensors are mounted on the shell and are accessible via the circumferential mounted stairway. Both the high and high-high level sensors use the same float switch chamber. A mid platform is provided to facilitate inspection and maintenance activities. The tank is also equipped with low and low-low sensors that are mounted in a single chamber. The High-High Level Sensor (HHLS), High Level Sensor (HLS), the Low

Level Sensor (LLS) and the Low-Low Level Sensor (LLLS) output to a multiple point liquid level control system display located in the control room. The tank is also equipped with a

High Liquid Level Shut-Off Valve (HLV) that is actuated by a shell mounted HLV float pilot.

Alarms, horns, and the associated indictor system were tested during this inspection. The facility also conducts periodic facility wide preventive maintenance testing of the alarms and ATG system. The overall general conditions of the level alarms are satisfactory (with some exception – See Section C).

e. Stairs and Platforms

The tank’s fixed roof is accessible by a circumferential stairway mounted on the shell of the tank with mid and top platforms. The stair and platform were inspected for corrosion and structural soundness. The stairway handrail is constructed with 1.5" angle iron handrails and steel plate threads with non-slip profile. The overall general condition of the stairs and platform are satisfactory (with some exceptions – See Section C).

f. Grounding and Bonding

There are five (5) grounding cables connected to the original bottom extension or the dead shell. A copper grounding sleeve for personnel static electric discharge is mounted on the handrail (typically required by military criteria).

5. Tank Coating

The tank shell, bottom projection, roof, stairway, handrails, piping, and appurtenances are coated. The exterior tank coating is an epoxy with a polyurethane top coat (beige in color) with an unknown completion date. The interior of the tank is also assumed to be completely coated (not inspected).

Accessible sections of the interior tank surfaces appear to be in good condition with no visible coating failure. Note: the stainless component including a section of the product piping was coated (Stainless steel is not to be coated per UFGS 33 523 43.13).

6. Tank Piping System

The fuel is received through 8-inch carbon steel piping with a CLA Val and DBB valve at the tank. The product is issued through 10-inch carbon steel piping. Other auxiliary piping for the water draw (NPS

3/4) and low suction (NPS 4) are installed. The NPS 3/4 water draw is attached to a Product Saver

Tank (PST) using welded carbon steel piping and threaded stainless steel piping. The low suction nozzle is equipped with a DBB valve that is configured in to the product suction piping. Inspected and evaluated each tank nozzle in accordance with API Standards 650 and 653. Identified the type and use of each shell nozzle on all accessible shell nozzles. Evaluated all nozzles and reinforcement plates for leaks and corrosion.

7. Fire Protection System

There are two (2) fire hydrants within 300 feet of the tank located along the property fence line and accessible to fire department pumper vehicles.

8. Secondary Containment

The tank sits inside a concrete secondary containment basin with concrete berm walls. The overall dimensions of the secondary containment is 100 feet x 80.5 feet (basin footprint), with a sloped berm and an average vertical height of 65.785 inches. The secondary containment is equipped with a 6" carbon steel drain pipe with a 32" x 17" x 8.5" drain area inlet. A drain valve is located on the south side of the berm wall and is operated with an extension pole. The valve drain pole was available at the time of the inspection. The secondary containment drain valve is secured with a lock.

The secondary containment was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation growth. Minor hairline cracks (temperature cracks) and some moderate cracks were noted in the secondary containment and are documented in the secondary containment layout. An approximate total of 42 linear feet of cracks in the secondary containment basin was identified. An additional 25 linear feet of cracks were located on the interior berm wall and 18 linear feet of cracks on the exterior berm wall. These cracks were classified as minor to moderate in crack appearance, and some include previously sealed cracks. The concrete secondary containment berm walkway has approximately 18 linear feet of minor to moderate cracks on the top section of the berm. Hairline cracks and cracks on top of the walking path do not seriously affect the strength of the concrete structures; however, these cracks can be potential access points for moisture or water seepage that could corrode the reinforcing steel (rebar). The preformed wedge type joint sealant for the secondary containment concrete floor wall expansion was replaced with polyurethane sealant. Some isolated deterioration was noted on the existing basin and wall sealant (mostly weathered). Some sections of the perimeter of the top of the berm is not sealed (mostly the north berm and the shared west berm).

The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage. The secondary containment is otherwise in serviceable and satisfactory mechanical condition, with the exception of the discrepancies summarized above and identified in Section C. Field assessment indicates that the secondary containment is of sufficient size to contain a total tank loss with approximately 382,970 gallons of containment capacity (216%). The secondary containment is sloped to allow for drainage away from the tank.

A formal secondary containment evaluation, in accordance with 40 CFR 112, may be required in order to satisfy federal, state, and local requirements. The secondary containment is equipped with a lockable secondary containment valve post indicator.

C. FINDINGS AND RECOMMENDATIONS

The tank is generally not in accordance with current military criteria for some of the tank appurtenance and piping configuration. Therefore, the recommendations are not meant to bring the tank into full compliance with UFC 3-460-01 or AW 78-24-27 standards but rather to identify these items for the owner/user’s planed upgrades, rehabilitation, and priority repairs. Mandatory repairs should be completed to assure compliance with industry standards, as well as federal or state jurisdictional requirements.

During this evaluation, the tank was found to be in a generally serviceable condition, with no imminent risk to operation and overall integrity. However, there were several deficiencies that were noted. These noted deficiencies are listed below in no particular order, with repair recommendations.

All repairs and modifications should be performed in accordance with API standard 653, UFC 3‐460‐01, DoD Standard Design 78‐24‐27, and applicable UFGS specifications.

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

Mandatory Repairs represent items that require immediate attention, in order to prevent imminent risk to system operators, equipment integrity, or the adjacent environment. The tank should remain out of service until these repairs are completed.

a. No Mandatory Repairs were identified for this tank.

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

Short-Term Repairs that directly relate to the long-term preservation of the asset. Short-Term Repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment. These items may be required by federal, state and local codes , or by military criteria.

a. Secondary Containment Basin Cracks

OBSERVATION: The concrete secondary containment basin has approximately 42 Linear Feet (LF) of unsealed cracks.

CODE REFERENCE: 40 CFR Section 112.7(c) states that the entire secondary containment system

“including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system ... will not escape containment before cleanup occurs.”

§§112.8(c)(2) and 112.12(c)(2) state that diked areas must be “sufficiently impervious to contain oil.”.

RECOMMENDATION: Repair all exposed cracks in the secondary containment basin.

b. Secondary Containment Wall Cracks (Interior Berm)

OBSERVATION: The concrete secondary containment berm has approximately 25 LF of minor to moderate cracks on the interior section of the wall.

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

RECOMMENDATION: Repair all exposed cracks in the secondary containment berm.

c. Secondary Containment Wall Cracks (Previously Sealed Areas)

OBSERVATION: The concrete secondary containment berm has approximately 18 LF of failed sealant on previously repaired cracks on the interior and top section of the wall.

RECOMMENDATION: Repair all failed crack sealant in the secondary containment berm.

d. Secondary Containment Walk way Cracks (Top of Berm)

OBSERVATION: The concrete secondary containment berm walkway has approximately 18 LF of minor to moderate cracks on the top section of berm.

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

e. Secondary Containment Wall Cracks (Exterior Berm)

OBSERVATION: The concrete secondary containment berm has approximately 75 LF of minor to moderate cracks on the exterior section of the wall.

f. Secondary Containment Sealant Deterioration (Previously Sealed Areas)

OBSERVATION: The concrete secondary containment has approximately 33 LF of failed control joint sealant that was previously repaired on floor and berm wall.

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

RECOMMENDATION: Replace all deteriorated sealant and backer rod if applicable in the secondary containment floor and berm.

g. Secondary Containment Walk way Cracks Sealant (Top of Berm)

OBSERVATION: The section of the perimeter on the top of the berm is not sealed (200 LF). The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage.

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

RECOMMENDATION: Install sealant in the secondary containment berm walkaway perimeter

(Quantity. 200 LF, mostly on the north side).

h. Circumferential Stairway Clearance (Previously Modified)

OBSERVATION: The circumferential stairway has inadequate clearance between the handrail and the high level alarm chamber. The existing clearance between the chamber and handrail is 18.5 inches.

29 CFR 1910.24(d) requires a minimum width of 22 inches.

CODE REFERENCE: OSHA 29 CFR 1910.24(d)

RECOMMENDATION: Reconfigure the high level alarm chamber or expand the intermediate platform to allow for sufficient clearance to meet OSHA 29 CFR 1910.24(d).

i. No Confined Space Markings at Manholes

OBSERVATION: The tank is not equipped with a confined space marking.

CODE REFERENCE: In accordance with OSHA Regulation 29 CFR 1910.146(c)(2), “If the workplace contains permit spaces, the employer shall inform exposed employees, by posting danger signs or by any other equally effective means, of the existence and location of and the danger posed by the permit spaces. NOTE: A sign reading DANGER -- PERMIT-REQUIRED CONFINED SPACE, DO NOT ENTER or using other similar language would satisfy the requirement for a sign.”

RECOMMENDATION: Install confined space markings on all tank entry points.

j. Product Saver Tank (PST) Grounding

OBSERVATION: The Product Saver Tank is not grounded at the leg.

CODE REFERENCE: In accordance with NFPA-30, paragraph 6.5.4, “All equipment such as tanks, machinery, and piping shall be designed and operated to prevent electrostatic ignitions. All metallic equipment where an ignitable mixture could be present shall be bonded or grounded. The bond or ground or both shall be physically applied or shall be inherently present by the nature of the installation.” Additionally, see AW 78‐24‐27 Drawing D.13 Detail 5

RECOMMENDATION: Install a ground cable to the Product Saver Tank in accordance with AW 78‐24‐27

Drawing D.13 Detail 5 (Quantity: 1). Note: The detail also notes the PST should have a housekeeping pad and hi & hi-hi alarms

k. Conduit Seal-Off at the ENRAF Tank Side Indicator

OBSERVATION: The conduit of the tank side indicator of the ENRAF automatic tank gauge does not have a conduit seal-off.

CODE REFERENCE: Article 501 of NFPA-70

RECOMMENDATION: Install seal-off with sealing compound in the conduit of the tank side indicator of the ENRAF automatic tank gauge to maintain the Class 1, Division 2 rating requirements for hazardous locations in accordance with the manufacturer’s standards and the National Electrical

Code (NEC) in Article 501, Section 501-5 (Quantity: 1 seal-off).

l. Loose Conduit Cover on the ENRAF Tank Side Indicator

OBSERVATION: The T-style conduit outlet body cover is loose on the TSI.

CODE REFERENCE: Article 501 of NFPA-70

RECOMMENDATION: Ensure the conduit cover is secured to maintain Class 1, Division 2 rating requirements for hazardous locations.

m. Conduit Seal-Off (Containment Exit)

OBSERVATION: There are no seal-offs provided for the tank equipment conduits at the secondary containment exit area. Seal-off is required where the NFPA electrical classification of the area changes, such as where it leaves the secondary containment.

CODE REFERENCE: Article 501 of NFPA-70 lists the requirements for Class I hazardous locations sealing requirements. The purpose of the seal is to “minimize the passage of gases and vapors and prevent the passage of flames from one portion of the electrical installation to another through the conduit..”

RECOMMENDATION: Install seal-off in locations where boundaries change. A conduit seal is required in each conduit run leaving a Class I, Division 2 location.

n. Conduit Seal-Off Enraf ATG

OBSERVATION: There are no seal-offs provided for the ATG conduits. Seal-off is required where the

NFPA electrical classification of the area changes, such as where it is mounted on roof near openings.

CODE REFERENCE: Article 501 of NFPA-70 lists the requirements for Class I hazardous locations sealing requirements. The purpose of the seal is to “minimize the passage of gases and vapors and prevent the passage of flames from one portion of the electrical installation to another through the conduit.”

each conduit run leaving a Class I, Division 2 location.

o. Conduit Seal-Off at VITO Water Probe

OBSERVATION: There are no seal-offs provided for the VITO automatic tank gauge water probe mounted on the roof. Seal-off is required where the NFPA electrical classification of the area changes, such as where it is mounted on roof near openings.

CODE REFERENCE: Article 501 of NFPA-70 lists the requirements for Class I hazardous locations sealing requirements. The purpose of the seal is to “minimize the passage of gases and vapors and prevent the passage of flames from one portion of the electrical installation to another through the conduit.”

each conduit run leaving a Class I, Division 1 location.

p. Conduit Seal-Off Level Alarms Chamber Conduits

OBSERVATION: Both the HLA/HHLA and LLA/LLLA conduits are not equipped with conduit seal-offs

CODE REFERENCE: Article 501 of NFPA-70 lists the requirements for Class I hazardous locations sealing requirements. The purpose of the seal is to “minimize the passage of gases and vapors and prevent the passage of flames from one portion of the electrical installation to another through the conduit.”

RECOMMENDATION: Install seal-offs with sealing compound in the conduit of HLA/HHLA and

LLA/LLLA conduits to maintain the Class 1, Division 2 rating requirements for hazardous locations in accordance with the manufacturer’s standards and the National Electrical Code (NEC) in Article 501, Section 501-5.

q. Mechanical Tape Gauge Attached to the IFR

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

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

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

r. No Scaffold Cable Supports

OBSERVATION: The tank does not have two scaffold cable supports installed on the fixed roof in accordance with UFC 3-460-01 and API STD 650.

CODE REFERENCE: UFC 3-460-01 Table 8-1 Item (jj) and API STD 650

RECOMMENDATION: Install two scaffold cable supports in accordance with UFC 3-460-01 Table 8-1

(jj) and API STD 650 (Quantity: 2).

s. Hold‐Off Distance OBSERVATION: There is no “hold off distance” stenciled or painted at the manual tank gauge/sample hatch on the roof.

CODE REFERENCE: General maintenance/API STD 653 Checklist Item (C.1.5.1 (d) ‐ check for marker and tab stating hold‐off distance)

RECOMMENDATION: Stencil or paint the “hold off distance” at the manual tank gauge hatch.

t. Circulation/Inspection Hatch Screen (Insect Screen) OBSERVATION: The circulation vent/inspection hatch screens are equipped with coarse mesh screen with an insect screen. API 650 and industry standards recommend the use of corrosion-resistant coarse-mesh screens to reduce the possibility of clogging.

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

RECOMMENDATION: Remove all insect screens (Quantity: 3 circulation/inspection hatches).

u. Shell Attachment and Spacing (Circumferential Stairway Treads) Not per Code OBSERVATION: Two of the stairway treads were welded on or very close to the tank horizontal seam.

This does not meet good engineering practice and current API standard.

CODE REFERENCE: API 650 Section 5.8.1.2(a) “Permanent attachments may be welded directly to the shell with fillet welds having a maximum leg dimension of 13 mm (1/2 in.). The edge of any permanent attachment welds shall be at least 75 mm (3 in.) from the horizontal joints of the shell and at least 150 mm (6 in.) from the vertical joints, insert-plate joints, or reinforcing-plate fillet welds.”

RECOMMENDATION: The tank has demonstrated a history of service without failure at the welds, but routine Magnetic Particle inspection should be included as part of the inspection program until future upgrades are made (particularly after seismic events or after any abnormal tank condition). The stairway treads can be mounted to a reinforcement pad that is seal-welded to the shell meeting the spacing requirement of API Std. 653.

3. RECOMMENDED REPAIRS as Part of Regular Maintenance

Long-Term Repairs that directly relate to repair/upgrade of an asset to bring it up to the current standard from the standard at time of construction. Long-Term Repairs represent items that should be addressed in a timely manner in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. Sample Gauge Latch OBSERVATION: The sample gauge well has 2 latches that do not engage to secure the floating seal receiver.

CODE REFERENCE: AW 78-24-27 Drawing D.07 Detail 2

RECOMMENDATION: Adjust or replace the latches.

b. Water Draw-Off Line Configuration OBSERVATION: The 1-inch water draw-off line has threaded stainless steel piping and does not have a

2-inch double-block and bleed valve at the tank (currently is a 3/4-inch ball valve). The water draw-off line is not flanged at the shell and has a stainless steel to carbon steel threaded coupling on the shell. Dissimilar metal threaded couplings could leak over time.

CODE REFERENCE: UFC 3-460-01 3-6 item (i) and AW 78-24-27 Drawing D.13 Detail 5

RECOMMENDATION: Install welded and flanged piping and a 2-inch double- block and bleed valve for the 1-inch water draw line in accordance with AW 78- 24-27 Drawing D.13 Detail 5 (Quantity: 1).

c. Mechanical Tape Gauge Bracket Weld (No Repad)

OBSERVATION: The shell mounted MTG supports do not have mounting plates seal-welded to the shell. Some porosity was noted on accessible sections of the MTG bracket (coating removal required to perform PT or MT).

CODE REFERENCE: AW 78-24-27 Drawing D.07 Detail 1

RECOMMENDATION: Future upgrades should consider installing mounting plates for all shell attached appurtenances/supports clips.

d. Shell Manhole is Equipped With Hinges (No Davit Arms)

OBSERVATION: The shell manhole covers are a hinged type with no davit arm. These types of hinged manhole covers are prone to shear damage of the pins, particularly on hinges without grease fittings.

CODE REFERENCE: API STD 650 Section 5.8.3.5 states, “Those covers weighing more than 34 kg (75 lb) shall be equipped with either a hinge or davit to facilitate the handling of the manhole cover plate.

The davit support arm shall not be welded directly to the shell without a reinforcing plate.” Also, AW

78‐24‐27 Drawing D.10 Detail 3

RECOMMENDATION: Install shell manhole davit arms in accordance with API STD 650 and AW

78‐24‐27 Drawing D.10 Detail 3.

e. Faded Tank Marking (NFPA Diamond)

OBSERVATION: The NFPA diamond placard is faded. The fire hazard (red box) and the reactivity

(yellow box) are faded.

CODE REFERENCE: In accordance with NFPA 30 paragraph 21.7.2.1, “A sign or marking that meets the requirements of NFPA-704, Standard System for the Identification of the Hazards of Materials for

Emergency Response, or an equivalent system, shall be applied to storage tanks containing liquids.”

RECOMMENDATION: Install an NFPA-704 marking.

f. HLV Solenoid Flex Conduit

OBSERVATION: The flexible conduit to the High Liquid Level Shut-off Valve (HLV) pilot solenoid is resting on the Cla Val body. Minor abrasion damage was noted.

CODE REFERENCE: General maintenance/Good engineering practice.

RECOMMENDATION: Adjust the conduit pipe support.

g. Conduit Unistrut Clamps

OBSERVATION: Three conduits at the northeast berm pipe penetration are missing conduit support clamps.

CODE REFERENCE: General maintenance/Good engineering practice

RECOMMENDATION: Reinstall the unistrut conduit clamps.

h. Over Voltage Protection Device

OBSERVATION: Both the receipt and issue lines are equipped with Over Voltage Protection (OVP) devices. The OVP on the issue line was resting on top of the flange at the time of the inspection. The tank is not equipped with a CP system.

CODE REFERENCE: General maintenance/Good engineering practice.

RECOMMENDATION: Remove the OVPs.

i. Thermal Relief Valve (TRV) Manufacturer Nameplate Painted

OBSERVATION: The manufacturer data plates on the receipt and issue for the thermal relief vlaves are covered with paint.

CODE REFERENCE: General maintenance/Good engineering practice. IAW ASME BPVC Section VIII, Division 1, Paragraph UG-129, “Each safety, safety relief, relief, liquid pressure relief, and pilot operated pressure relief valve NPS 1⁄2 (DN 15) and larger shall be plainly marked by the

Manufacturer or Assembler with the required data in such a way that the marking will not be obliterated in service. The marking may be placed on the valve or on a plate.” Additionally, IAW with

API 576 Section 6.2.3, “Each TRV should carry an identifying tag, stencil plate, or other means to show its company equipment number which also identifies the set pressure and other valve parameter (ie

ASME UG-129 marking). “

RECOMMENDATION: Remove paint from TRV the data plates.

j. Coated Stainless Steel Piping/Flange

OBSERVATION: A section of the stainless steel product piping (ball joints) and flanged appurtenances is coated.

CODE REFERENCE: UFGS 33 52 43.13 (Section 2.1.3)

RECOMMENDATION: Do not paint stainless steel or aluminum surfaces (Quantity: 4).

k. DBB Limit Switches

OBSERVATION: The tank DBB valves are not equipped with limit switches.

CODE REFERENCE: AW 078-24-27 Drawing ED.05, Item B.1

RECOMMENDATION: Provide DBB valves with limit switches to indicate valve position (whether manual or motor operated).

l. IFR Access Shell Manhole

OBSERVATION: The tank is not equipped with a shell manhole located above the internal floating pan’s high position to aid in venting the tank during cleaning and to provide access to the floating pan’s elastomeric wiper seals as required by DoD Standard AW 078-24-27.

CODE REFERENCE: UFC 3-460-01 Table 8-1 item c

RECOMMENDATION: Provide a shell manhole if needed (See UFC 3-460-01 Section 12-3.2 for caution statement and additionally the tank shell is 3/16-inches thick and requires moderate modification as well as insert plates to accommodate this UFC requirements).

m. Circulation Vent/Inspection Hatch

OBSERVATION: The circulation/inspection hatch is constructed out of carbon steel and does not meet the shape and material listed on the current DoD Standard AW 078-24-27. Minor coating failure and corrosion were noted on the hinges and underside of the air scoops.

CODE REFERENCE: AW 078-24-27 Drawing D.09, detail 1

RECOMMENDATION: Provide circulation/inspection hatch as detailed in AW 078-24-27.

APPENDIX A: ENGINEERING CALCULATIONS AND DRAWINGS

A.1 SHELL SERVICE LIFE EVALUATION

A.2 SHELL SETTLEMENT EVALUATION

A.3 ULTRASONIC UT DATA

A.4 SHELL LAYOUT DRAWING

A.5 ROOF LAYOUT DRAWING

A.6 CONTAINMENT LAYOUT DRAWING

A.7 OSHA ACCESS STRUCTURE REPORT

Shell Service Life Evaluation

Where:

t min = minimum acceptable shell thickness for each course, in inches; however, t min shall not be less than 0.1 inch for any tank course.

t nom = nominal shell thickness, in inches.

t act = current measured shell thickness, excluding pits and corrosion, in inches.

t prev = previous measured shell thickness, excluding pits and corrosion or t nom , in inches.

D = nominal diameter of the tank, in feet.

H = height from the bottom of the shell course under considerations to the established maximum liquid level, in feet.

H c = calculated safe fill height, in feet, for the current product.

G = specific gravity of the contents.

Y = specified minimum yield strength of the plate; use 30,000 pounds per square inch if not known

(N/A for riveted tanks).

T = smaller of the specified minimum tensile strength of the plate or 80,000 pounds per square inch;

use 55,000 psi if not known (N/A for riveted tanks).

S = The maximum allowable stress, in pounds per square inch. For welded tanks, use the smaller of

0.80Y or 0.429T for the bottom and the second course or the smaller of 0.88Y or 0.472T for all other courses. For riveted tanks, use S =21,000 psi. For elevated temperatures above 200 O F, the maximum allowable stress shall be the smaller of 2/3 the minimum yield strength multiplied by the M-factor (M) of API Standard 650 Appendix M or the product design stress value listed in

Table M-1a or M-1b of API Standard 650.

E = original joint efficiency for the tank. Use Table 4-2 from API Standard 653 if original E is unknown; E =1.0 when evaluating the retirement thickness in a corroded plate, when away from welds or joints by at least the greater of one inch or twice the plate thickness. For riveted tanks, use E =1.0 for shell plates when greater than 6 inches from rivets; use the value of E from API

Standard 653 Table 4-3 when within 6 inches of rivets.

L r = remaining life of the shell, in years.

C r =

I ut = inspection interval for the next ultrasonic inspection, in years (not to exceed 15 years).

I v = inspection interval for the next visual external inspection, in years (not to exceed 5 years).

Y = years between the previous measured shell thickness (t prev ) and the current measured shell thickness (t act ), in years.

The maximum inspection intervals are determined by the most restrictive shell course in regard to the remaining life and the corrosion rate calculations for each shell course using the following formulas:

tmin =

2.6(H−1)DG

SE

Lr = tact − tmin

Cr Cr = tprev − tact

Y Iut = tact − tmin

2Cr Iv = tact − tmin

4Cr

1) Minimum Required Thickness

D = 35 feet

G = 0.84

Y = 68 years

Course

No.

Plate

Specification

Course

Height

(feet)

Product

Height

(feet)

(H )

Maximum

Allowable

Stress

(psi)

(S )

Joint

Efficiency

(E )

Minimum

Acceptable

Thickness

(inches)

(t min )

Previous

Measured

Thickness

(inches)

(t prev )*

Current

Measured

Thickness

(inches)

(t act )

1 Unknown 5.17 24.58 23,600 0.85 0.1 0.1875 0.166

2 Unknown 5.92 19.41 23,600 0.85 0.1 0.1875 0.184

3 Unknown 5.92 13.50 26,000 0.85 0.1 0.1875 0.186

4 Unknown 5.92 7.58 26,000 0.85 0.1 0.1875 0.187

5 Unknown 5.92 1.66 26,000 0.85 0.1 0.1875 0.182

*The t prev values were based on t nom .

0.000

0.050

0.100

0.150

0.200

1 2 3 4

In ch es

Course

Thickness Graph tprev tact tmin

2) Corrosion Rate, Remaining Life and Inspection Intervals

Course

No.

Corrosion

Rate

(in./yr)

(C r )

Remaining

Life

(years)

(L r )

Next

Visual

Inspection

(years)

(I v )

Next

Ultrasonic

Thickness

Inspection

(years)

(I ut )

0.00032 208 5 15

2 0.00005 1632 5 15

3 0.00002 3898 5 15

4 0.00001 11832 5 15

5 0.00008 1013 5 15

* Let C r =0.0002 inches per year for calculation purposes.

Note: The engineering data used to calculate in-service period of operation (Remaining Life) assumes the tank remains in the same service and all corrosion rates remain constant. The maximum safe fill height for the tank is not limited other than by the established maximum operating liquid level and any other appurtenance such as overflow, vents, or firefighting system.

0.00000

0.00005

0.00010

0.00015

0.00020

0.00025

0.00030

0.00035

1 2 3 4 5

In ch es P er Y ea r

Course

Course Corrosion Rate Graph

Corrosion Rate

3) Projected Thickness Chart and Graph

Course #1:

Year Thickness tmin

2020 0.166 0.1

2025 0.164 0.1

2030 0.163 0.1

2040 0.160 0.1

2050 0.157 0.1

*based on same service and corrosion rates.

Course #2:

Year Thickness tmin

2020 0.184 0.1

2025 0.184 0.1

2030 0.183 0.1

2040 0.183 0.1

2050 0.182 0.1

*based on same service and corrosion rates.

Current Thickness:

Current Thickness:

Anticpated Thickness (5 yrs)*

Anticpated Thickness (10 yrs)*

Anticpated Thickness (20 yrs)*

Anticpated Thickness (30 yrs)*

Anticpated Thickness (5 yrs)*

Anticpated Thickness (10 yrs)*

Anticpated Thickness (20 yrs)*

Anticpated Thickness (30 yrs)*

0.000

0.050

0.100

0.150

0.200

2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

In ch es

Year

Course #1 Projected Thickness Graph

Thickness tmin

0.000

0.050

0.100

0.150

0.200

2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

In ch es

Year

Course #2 Projected Thickness Graph

Thickness tmin

Course #3:

Year Thickness tmin

2020 0.186 0.1

2025 0.186 0.1

2030 0.186 0.1

2040 0.186 0.1

2050 0.185 0.1

*based on same service and corrosion rates.

Course #4:

Year Thickness tmin

2020 0.187 0.1

2025 0.187 0.1

2030 0.187 0.1

2040 0.187 0.1

2050 0.187 0.1

*based on same service and corrosion rates.

Current Thickness:

Anticpated Thickness (5 yrs)*

Anticpated Thickness (10 yrs)*

Anticpated Thickness (20 yrs)*

Anticpated Thickness (30 yrs)*

Anticpated Thickness (20 yrs)*

Anticpated Thickness (30 yrs)*

Current Thickness:

Anticpated Thickness (5 yrs)*

Anticpated Thickness (10 yrs)*

0.000

0.050

0.100

0.150

0.200

2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

In ch es

Year

Course #3 Projected Thickness Graph

Thickness tmin

0.000

0.050

0.100

0.150

0.200

2020 2022 2024 2026 2028 2030 2032 2034 2036 2038 2040 2042 2044 2046 2048 2050

In ch es

Year

Course #4 Projected Thickness Graph

Course #5:

Year Thickness tmin

2020 0.182 0.1

2025 0.182 0.1

2030 0.181 0.1

2040 0.180 0.1

2050 0.180 0.1

*based on same service and corrosion rates.

Anticpated Thickness (30 yrs)*

Current Thickness:

Anticpated Thickness (5 yrs)*

Anticpated Thickness (10 yrs)*

Anticpated Thickness (20 yrs)*

0.000

0.050

0.100

0.1…