J.4_SCT-FAC 8733-FY20-Final.pdf

API-653 Out-Of-Service Inspection Scott Air Force Base April 23, 2020 Final Tank 33(FACILITY 8733)

US Army Corps of Engineers Omaha District

API 653 Out-of-Service Inspection Report

Scott Air Force Base; St. Clair County, Illinois Facility 8733

Tank 33

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

(USACE POL-MCX)

April 23, 2020

API 653 Out-of-Service Inspection Report Scott AFB, Illinois

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION DATE

STATE REGULATIONS

PREVIOUS INSPECTION DATES

RECOMMENDED FUTURE INSPECTION DATES – AFTER REPAIRS (CALCULATIONS SHALL BE PROVIDED)

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Tank Foundation

3. Tank Bottom

4. Tank Shell

5. Tank Appurtenances

6. Tank Coating

7. Tank Piping System

8. Fire Protection System

9. Secondary Containment

10. Cathodic Protection

C. FINDINGS AND RECOMMENDATIONS

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

2. REQUIRED REPAIRS to Fully Comply with API 653, 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 BOTTOM SERVICE LIFE EVALUATION

A.2 SHELL SERVICE LIFE EVALUATION

A.3 SHELL SETTLEMENT EVALUATION

A.4 ULTRASONIC UT DATA

A.5 BOTTOM LAYOUT DRAWING

A.6 SHELL LAYOUT DRAWING

A.7 ROOF LAYOUT DRAWING

A.8 CONTAINMENT LAYOUT DRAWING

A.9 OSHA ACCESS STRUCTURE REPORT

APPENDIX B: 3-D DOCUMENTATION AND ANALYSIS

APPENDIX C: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX D: PHOTOGRAPHS

ACRONYMS AND ABBREVIATIONS

API American Petroleum Institute

ASME American Society of Mechanical Engineers

ASNT American Society of Non-Destructive Testing

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 internal inspection, out-of-service, of Tank 33 (Facility 8733) at Scott AFB, Illinois was completed on April 23, 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. Two areas of underside corrosion indications were identified on the tank bottom. Area of Underside Corrosion with Tmin = 0.130" on Plate 5 and an area of Underside Corrosion with Tmin = 0.217" on Plate 8.

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

a. The ladder support pad does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

b. The diffuser pipe support pad does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

c. The old welded-on steel striker plates do not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

d. The issue pipe support does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

e. The diffuser support pad is not rounded per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

f. The issue pipe support pads do not have rounded corners as required per Section 9.10.3 and Figure

9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

g. The low suction pipe support pads do not have rounded corners as required per Section 9.10.3 and

Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

h. The internal product piping supports for the receipt line are an adjustable type with loose TEFLON coated U-bolts. The diffuser is not resting on the pipe support.

i. The internal product piping supports for the 10-inch issue line are not an adjustable type without loose TEFLON coated U-bolts. The issue line is not resting on the pipe support.

j. The concrete secondary containment basin has approximately 45 Linear Feet (LF) of unsealed cracks.

k. The concrete secondary containment berm has approximately 95 LF of minor to moderate cracks on the interior section of the wall.

l. The concrete secondary containment berm walkway has approximately 20 LF of minor to moderate cracks on the top section of the berm.

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

n. The concrete secondary containment utilizes a preformed wedge type joint sealant. Edge separation and some lifting were noted throughout the secondary containment. The NPS 3 pipe support penetration through the basin slab has minor sealant deterioration.

o. The entire perimeter of the top of the berm is not sealed. The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage. One section of the exterior berm slab was noted to have lifted off slightly.

p. The circumferential stairway has inadequate clearance between the handrail and the high level alarm chamber. The existing clearance between the chamber and handrail is 17 inches. 29 CFR

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

q. The shell manhole covers area hinged type with no davit arms. The east shell manhole has a broken cover hinge.

r. The 8-inch high liquid level shut-off valve is cast aluminum. The HLV was painted at the time of the inspection.

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

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

u. The tank is equipped with a personnel static grounding copper material, but it was coated at the time of the inspection AW 78-24-27.

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

w. A VISI-FLOW glass sight flow indicator is present on the 10-inch issue piping thermal relief line.

Glass sight flow indicators are not allowed on fuel systems.

x. A VISI-FLOW glass sight flow indicator is present on the 8-inch receipt line thermal relief line. Glass sight flow indicators are not allowed on fuel systems.

y. The existing mechanical tape gauge Varec (Model 2500) is not per the manufacturer’s 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.

z. 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.

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

bb. The NPS 10 issue valve has one stud that is not engaged into the Double-Block and Bleed (DBB) valve flange. The stud length was verified to be five inches long with UT (studs that thread to DBB valve flange).

cc. The mid rail is removed at four locations to facilitate room for the circulation vent/inspection hatch cover. There is no safety chain installed at these locations.

dd. Three of the stairway treads were welded on or very close to the tank horizontal seam.

ee. The concrete ringwall has isolated minor hairline cracks.

ff. There is isolated sealant failure between the tank bottom projection (chime) to ringwall interface.

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

Regular Maintenance:

a. The ENRAF fuel level probe and VITO water probe share a common 8-inch stilling well.

Entanglement could damage the systems and provide inaccurate measurements. The VITO water probe should be in a separate stilling well that is near the sump.

b. The sample gauge well does not have a sample gauge hatch on top of the stilling well. The gauge well is only accessible by opening the roof hatch on top of the roof or by unbolting a flanged cover.

c. The 1-inch water draw-off line is threaded stainless steel piping and does not have a 2-inch double-block and bleed valve at the tank (currently is a 1-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.

d. The 8-inch receipt line, 10-inch issue, 4 inch low suction, and ¾" water draw are not equipped with a flange on the interior of the tank.

e. The 8-inch receipt line diffuser is not configured per standard design (not slopped down and is elevated 12 inches above the tank bottom).

f. The tank piping within the dike does not have yellow bands/product symbols and directional arrows.

g. The 3/4-inch water draw-off line internal pipe supports do not have adjustable “H” type internal pipe supports and do not have TEFLON coated U- bolts. The water draw-off line is not flanged at the shell.

h. The thermal relief valve piping for the issue and receipt lines are not designed to current military standards. They do not have test tees, inlets are ¾", and it is not stainless steel piping. No historical data was available indicating annual calibration was performed. The data plate is painted on the issue TRV and missing on the receipt TRV.

i. Two sets of aluminum stairs are located inside the containment. These stairs are used for access over the top of the tank’s piping. The stairs are unstable with a pronounced wobble when using them and are determined to be unsafe. The stairs are anchored to the containment floor.

j. The ground cables are bolted to the ground lug on the shell and are not exothermically welded to the ground lug with a reinforcement pad.

k. The existing nozzle and piping configuration on the HLA/HHLA chamber does not allow fuel to drain from the chamber and requires operators to manually drain the system to assure a functional alarm system.

l. The tank is not equipped with a low-low level sensor.

m. The tank is equipped with an 8-inch aluminum stilling well. The slots on the stilling well do not meet the current design standard. The slots measure 1" wide x 6" long spaced every 6".

n. There are isolated coating failure and corrosion noted on the inner circumferential stairway handrail.

o. The shell mounted MTG supports do not have mounting plates seal-welded to the shell. Small stress coating cracks were noted at the weld (coating removal required to perform PT or MT).

p. The tank bottom is not equipped with telltale drain valves. The bottom leak detection telltale drains are equipped with plugs. The plugs are open.

q. The independent high level alarm assembly does not have 1inch piping extending to the Product

Saver Tank (PST).

r. The issue line is not equipped with an anti-vortex plate welded to the end of the pipe.

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

(Aboveground aluminum and stainless steel materials are not to be coated).

t. The low suction nozzle is not equipped with a DBB valve and is not configured as shown in AW 07-

24-27.

u. Both receipt and issue lines are equipped with Over Voltage Protection (OVP) devices. The OVPs are nonstandard enclosures with exposed wires. The tank is not equipped with a CP system.

v. The tank DBB valves are not equipped with limit switches.

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

x. A small amount of water dripping was noted on top of the Internal Floating Roof (IFR) during a heavy rain event.

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

Standard AW 078-24-27. There is a link-lock that does not engage.

INSPECTION DATE

API Out-of-Service (Internal) Inspection Date: 23 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 Bottom Surveying Manufacturer: MFE Enterprises Model: 2412 Mark II Calibration Methods Used: Sensitivity adjacent on manufacturer supplied test plate with simulated anomalies and notch

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

Tank Shell Surveying Manufacturer: Leica Geosystem Model: 3D Disto Calibration Methods Used: Tilt sensor calibration automatically performed with unit set at < 3° and crosshairs calibration using target at a distance > 25 m

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: 6 October 2011 API In-Service (External) Inspection Date: 24 July 2017 Alteration/Repairs Completed: New tank bottom in 1996. ¾” nozzles w/ internal piping, 8” nozzle (diffuser), 10” nozzle w/ internal piping, two 8” gauge poles, 24” bottom sump, two 36” manholes

RECOMMENDED FUTURE INSPECTION DATES – AFTER REPAIRS (CALCULATIONS SHALL BE PROVIDED)

Routine In-service Inspections (API 653-6.3.1): Monthly (owner/operator personnel) External (Visual) Inspection (API 653-6.3.2): 23 April 2025 Ultrasonic Thickness Inspection (API 653 -6.3.3): 23 April 2035 Internal Inspection* (API 653 – 6.4): 23 April 2040

*20 yrs. for tanks without Release Prevention Barrier. 30 yrs. for tanks with Release Prevention Barrier. Note: UFC 3-460-03 indicates Internal (Out-of-Service API 653) inspection every ten (10) years.

The tank is not in suitable condition for return to service. The tank was not returned to service as of April 24, 2020 due to areas of underside corrosion marked for repairs with approximately 3.94 years of remaining life calculated on Bottom Plate # 5.

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

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner U.S Air Force

Location Scott AFB

Facility Number 8733

Tank Number 33

State / Country Illinois/USA

City St Clair County

Inspection Date April 23, 2020

Tank Manufacturer Graver Tank and Manufacturing Co.

Design Standard API-12 C (Assumed)

Date of Construction 1952

Tank Contents Jet Fuel (F-24)

Tank Serial Number Unknown

Tank Diameter 35 feet

Shell Height 28 .83 feet

Product Height 24’ 8"

Tank Capacity 4,238 BBL ( 178,005 Gallons)

Foundation Concrete Ringwall

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 Epoxy

Exterior Coating System Epoxy with a polyurethane top

Level Gauging Enraf servo ATG, Vito water probe, and manual gauging in one 8” 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" (No Piping) (Ball valve and Camlock Fittings)

Water Draw-Off ¾" Welded CS and threaded SS

Level Alarms High-High Level Alarm: 23' 11-00/16"(Independent) 24' 00-02 /16" (ATG) High Level Alarm: 23' 2-00/16"(Independent) 23' 03-14 /16" (ATG) Low Level Alarm: 2' 02-00/16" (Independent) 2' 04-04 /16" (ATG) Low-Low Level Alarm: None (Independent) 1' 02-14 /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 internal inspection, out-of-service, was performed for Tank 33 (Facility 8733).

2. Site Information

On April 23, 2020 InterSpec, LLC under contract to Argus Consulting Inc. performed an internal inspection, out-of-service, of Tank 33 (Facility 8733) 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 33 (Facility 8733) is used as an aboveground fuel storage tank supporting the installation fueling needs.

B. TANK INSPECTION COMMENTS

1. Tank Construction

Tank 33 (Facility 8733) is a nominal 4,238 BBL (178,005 Gallon), 35‐foot diameter by 28.83‐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.

2. Tank Foundation

The tank sits on a concrete pad foundation that is elevated approximately 1 ½” inches above the secondary containment floor. The foundation is not equipped with a leak detection (tell‐tale) system that extends through the ringwall. However leak detection ports are mounted on the dead shell elevated above the original tank bottom. Accessible sections of the foundation were visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank. No vegetation was present, but there were minor hairline cracks. The bottom plate extension on the original tank bottom (chime) is sealed and is in mostly satisfactory condition with isolated deterioration. The foundation has minor hairline cracking. A shell settlement survey was performed in accordance with Annex B of API Standard 653. The foundation has minor settlement within API limits

3. Tank Bottom

The bottom is constructed from carbon steel material of unknown specification. The bottom is a cone-down design, lap-welded together, consisting of sixteen (16) plates lap-welded together and fillet-welded to the shell. The bottom has a thin film interior liner. The interior coating was evaluated for dis-bonding, adhesion, deterioration, and discoloration and was found to be in satisfactory condition. A close visual inspection of all the welded-on plates was performed for indications of cracked welds, cracked coating, and capillary effects of residues. Dry film thickness (DFT) readings typically ranged between 13-25 mils.

Evaluated the bottom, bottom welds, and bottom‐to‐shell weld for corrosion, with no other discrepancies noted other than weld spacing and size noncompliance with API Standard 653.

Performed a magnetic flux leakage (MFL) evaluation of the tank bottom to determine the condition of the underside; ninety‐five plus percent was scanned. Several areas indicating underside corrosion were located and proved up; see Section C (1)(a) below and the Bottom Drawing in Appendix A for location data. An ultrasonic inspection of the bottom suggests an original nominal thickness of 0.3125".

4. Tank Shell

The tank shell is constructed from carbon steel material of an unknown specification. The shell is of cylindrical design, butt-welded together, and consisting of 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 level alarm, high level alarm, high-high level alarms, as well as a high-level shut-off.

5. Tank Appurtenances

a. Internal Floating Roof

The tank is equipped with a PETREX internal floating roof. The floating roof is of aluminum honeycomb construction. The primary and secondary double wiper seals along with roof opening gaskets were inspected for tears and deterioration. A section of deteriorated wiper seals and penetration gaskets were noted. The floating roof primary and secondary double wiper seals and penetration gaskets were replaced as part of this inspection. New PTEF plug inserts were also added to the floating roof legs.

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 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 #766) 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 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 high and high-high level sensors use the same float switch chamber. The tank is also equipped with low sensor that is mounted in an individual chamber. The High-High Level Sensor (HHLS), High Level Sensor (HLS), and the Low Level

Sensor (LLS) 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. The 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 a top platform. The stair and platform were inspected for corrosion and structural soundness. The stairway handrail is constructed with 1.5" round pipe 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 six (6) 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 but was covered with coating (typically required by military criteria).

6. Tank Coating

The tank shell, bottom projection, roof, stairway, handrails, piping, and appurtenances are coated. The exterior tank coating is an epoxy with a polyurethane top coat (beige in color) with an unknown completion date. The interior of the tank is also completely coated. There is little to minor coating failure on the tank shell, with minor coating failure on the appurtenances and stair platform grating.

Note: the stainless component including a section of the product piping was coated (stainless steel is not to be coated per UFGS 33 52 43.13).

7. 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 ball valve and a Camlock fitting. Inspected and evaluated each tank nozzle in accordance with API Standards 650 and 653. Identified the type and use of each shell nozzle on all accessible shell nozzles. Evaluated all nozzles and reinforcement plates for leaks and corrosion.

8. Fire Protection System

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.

The tank is also equipped with full contact, aluminum honeycomb floating pan that serves as tank interior fire protection system.

9. 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 67.5 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 45 linear feet of cracks in the secondary containment basin was identified. An additional 95 linear feet of cracks were located on the interior berm wall and 25 linear feet of cracks on the exterior berm wall. These cracks were classified as minor to moderate in crack appearance. The concrete secondary containment berm walkway has approximately 20 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 sealant for the secondary containment concrete floor wall expansion and slab joints utilizes a preformed wedge type joint sealant with gaps at the interface. Edge separation and some lifting were noted throughout the secondary containment. The entire perimeter of the top of the berm is not sealed. The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage. One section of exterior berm slab was noted to have lifted off slightly (possibly from water freezing). 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 382,700 gallons of containment capacity (215%). The secondary containment is sloped to allow for drainage away from the tank.

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

10. Cathodic Protection

This tank currently does not have cathodic protection installed to protect the tank bottom from corrosion. Both the receipt and issue line are equipped with nonfunctioning Over Voltage Protection

(OVP) devices. The reason for the initial installation of the OVPs is unknown.

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.

The tank is not in suitable condition for return to service. The tank was not returned to service as of April 24, 2020 due to areas of underside corrosion marked for repairs with approximately 3.94 years of remaining life calculated on Bottom Plate # 5. There were several other deficiencies that were also noted. These noted deficiencies are listed in section 2 and Section 3 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. Underside Corrosion

OBSERVATION: Two areas of underside corrosion indications were identified on the tank bottom. Area of Underside Corrosion with remaining thickness of 0.130" on Plate 5 and an area of Underside Corrosion with remaining thickness of 0.217" on Plate 8.

CODE REFERENCE: API Standard 653 Section 4.4.5

RECOMMENDATION: Install weld-on repair plates over areas of underside corrosion locations per API Standard 653 Section 9.10 and inspect per API Standard 653 Section 12. (Quantity: 2 Weld-on plates).

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.

b. Ladder Support Pad Weld Spacing

OBSERVATION: The ladder support pad does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider replacing the support pad to meet the requirements of API standards to eliminate the requirement to

MT or PT examination during future API inspections (Quantity: 1 pad).

c. Diffuser Support Pad Weld Spacing

OBSERVATION: The diffuser pipe support pad does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13.

A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating (See additional comment about square corners).

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider replacing the support pad to meet the requirements of API standards to eliminate the requirement to

MT or PT examination during future API inspections (Quantity: 1 pad).

d. Old Welded-On Steel Striker Plates Weld Spacing

OBSERVATION: The old welded-on steel striker plates do not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13.

A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider

e. Issue Pipe Support Weld Spacing

OBSERVATION: The issue pipe support does not meet API Standard 653 requirements for spacing (2" minimum spacing from bottom weld seam required) per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating (See additional comment about square corners).

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider

f. Diffuser Support Pad Not Rounded (Square Cornered)

OBSERVATION: The diffuser support pad is not rounded per Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider

g. Issue Support Pads Not Rounded (Square Cornered)

OBSERVATION: The issue pipe support pads do not have rounded corners as required per Section

9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider

MT or PT examination during future API inspections (Quantity: 2 including abandoned pad).

h. Low Suction Support Pads Not Rounded (Square Cornered)

OBSERVATION: The low suction pipe support pads do not have rounded corner as required per

Section 9.10.3 and Figure 9.13. A close visual inspection of the welded-on plate and adjacent bottom lap-weld did not reveal any indications of cracked welds or cracked coating.

CODE REFERENCE: API Standard 653 Section 9.10.3 and Figure 9.13

RECOMMENDATION: Conduct magnetic particle (MT) or liquid penetrant (PT) examination by certified

ASNT-TC-1A technicians of the affected welds, as a follow-on to this inspection. Note: Consider

MT or PT examination during future API inspections (Quantity: 2).

i. Internal Piping Support (Receipt Diffuser)

OBSERVATION: The internal product piping supports for the receipt line are not an adjustable type with loose TEFLON coated U-bolts. The diffuser is not resting on the pipe support.

CODE REFERENCE: AW 78-24-27 Drawing D.08 Detail 6

RECOMMENDATION: Replace the receipt diffuser internal pipe supports in accordance with AW 78-24-

27 Drawing D.08 Detail 6 (Quantity 2).

j. Internal Pipe Support (Issue Line)

OBSERVATION: The internal product piping supports for the 10-inch issue line are an adjustable type but without loose TEFLON coated U-bolts. The issue line is not resting on the pipe support.

CODE REFERENCE: AW 78-24-27 Drawing D.08 Detail 6.

RECOMMENDATION: Adjust/modify the 10-inch issue line internal pipe supports in accordance with

AW 78-24-27 Drawing D.08 Detail 6 (Quantity: 2).

k. Secondary Containment Basin Cracks

OBSERVATION: The secondary containment basin has approximately 45 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.

l. Secondary Containment Wall Cracks (Interior Berm)

OBSERVATION: The concrete secondary containment berm has approximately 95 LF of minor to moderate cracks on the interior section of the wall. One area of edge cracking was noted on the interior side of the secondary containment staircase (second step from the bottom), measuring approximately 2.5 LF.

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

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

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

OBSERVATION: The concrete secondary containment berm walkway has approximately 20 LF of minor to moderate cracks on the top section of the berm.

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

n. Secondary Containment Wall Cracks (Exterior Berm)

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

o. Secondary Containment Basin Sealant Deterioration (All)

OBSERVATION: The concrete secondary containment utilizes a preformed wedge type joint sealant. It is not known if the slabs are equipped with water stop nor can their condition be verified. Edge separation and some lifting were noted throughout the secondary containment. NOTE: bubble formation noted at joint – circled in red). Localized water loss was noted at the joints after precipitation. The NPS 3 pipe support penetration through the basin slab has minor sealant deterioration.

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

p. Secondary Containment Walkway Crack Sealant (Top of Berm)

OBSERVATION: The entire perimeter of the top of the berm is not sealed. The gaps between the berms may allow water intrusion and promote rebar corrosion as well as freeze damage. One section of the exterior berm slab was noted to have lifted off slightly.

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

RECOMMENDATION: Install sealant and backer rod where applicable in the secondary containment berm walkway perimeter.

q. Circumferential Stairway Clearance

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 17 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 and bracket or expand the intermediate platform to allow for sufficient clearance to meet OSHA 29 CFR 1910.24(d).

r. Shell Manhole Covers with Broken Hinges (No Davit Arms)

OBSERVATION: The shell manhole covers are a hinged type with no davit arms. The east shell manhole has a broken cover hinge. Note: flanged face of manway is coated it may impact sealing.

CODE REFERENCE: API STD 650 Section 5.8.3.5 states, “Shell manhole covers shall have two handles.

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. Remove coating from flange mating surfaces.

s. High Liquid Level Shut-Off Valve (Low Melting)

OBSERVATION: The 8-inch high liquid level shut-off valve is cast aluminum. The HLV was painted at the time of the inspection.

CODE REFERENCE: In accordance with NFPA 30, Section 27.4.4,” low melting point materials cannot be used with storage tanks, within a diked area or drainage path of a tank storing a Class I, Class II, or

Class IIIA liquid…”

RECOMMENDATION: Replace the aluminum high liquid level shut-off valve with a ductile iron, steel, or stainless steel equivalent.

t. 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.

u. 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).

v. Personnel Static Electric Discharge

OBSERVATION: The tank is equipped with personnel static grounding copper material, but it was coated at the time of the inspection AW 78-24-27.

CODE REFERENCE: UFC 3-460-03 Section 2-3.2.1 and AW 78‐24‐27 Drawing D.11 Detail 4

RECOMMENDATION: Install a copper grounding bar for personnel static electric discharge at the base of the circumferential stairway.

w. 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 1 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).

x. Thermal Relief Line Configuration for Issue Line

OBSERVATION: A VISI-FLOW glass sight flow indicator is present on the 10-inch issue piping thermal relief line. Glass sight flow indicators are not allowed on fuel systems.

CODE REFERENCE: UFC 3-460-01 Section 9-3.5.1 and AW 78-24-27 Drawing D.10 Detail 4

RECOMMENDATION: Remove the glass sight flow indicator and check valve from the thermal relief line for the 10-inch issue line in accordance with AW 78-24-27 Drawing D.10 Detail 4 (Quantity: 1).

y. Thermal Relief Line Configuration for Receipt Line

OBSERVATION: A VISI-FLOW glass sight flow indicator is present on the 8-inch receipt line thermal relief line. Glass sight flow indicators are not allowed on fuel systems.

CODE REFERENCE: UFC 3-460-01 Section 9-3.5.1 and AW 78-24-27 Drawing D.10 Detail 4

RECOMMENDATION: Remove the glass sight flow indicator and check valve from the thermal relief line for the 8-inch receipt line in accordance with AW 78-24-27 Drawing D.10 Detail 4 (Quantity: 1).

z. Mechanical Tape Gauge Attached to the IFR

OBSERVATION: The existing mechanical tape gauge Varec (Model 2500) is not per manufacturer’s 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.

aa. 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).

bb. 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.

cc. Improper Fastener installation/Stud Engagement (Issue Line DBB) OBSERVATION: The NPS 10 issue valve has one stud that is not engaged into the DBB valve flange. The stud length was verified to be five inches long with UT (studs that thread to DBB valve flange).

CODE REFERENCE: API 570 Section 5.15, “Flange fasteners should be examined visually for corrosion and thread engagement.” Fasteners should be fully engaged. Any fastener failing to do so is considered acceptably engaged if the lack of complete engagement is not more than one thread.”

RECOMMENDATION: Replace the fasteners to meet industry/good engineer practice with studs that are fully engaged with one nut.

dd. Circulation Vent/Inspection Hatch Chain OBSERVATION: The mid rail is removed at four locations to facilitate room for the circulation vent/inspection hatch cover. There is no safety chain installed at these locations.

CODE REFERENCE: In accordance with OSHA 1910.23(a)(2), “Every ladderway floor opening or platform shall be guarded by a standard railing with standard toe board on all exposed sides (except at entrance to opening), with the passage through the railing either provided with a swinging gate or so offset that a person cannot walk directly into the opening.” Also AW 78-24-27 Drawing D.09, Detail

RECOMMENDATION: Install a chain across the perimeter rail posts.

ee. Shell Attachment and Spacing (Circumferential Stairway Treads) Not per Code OBSERVATION: Three 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.).