N6945022R0002_J_1502000_11_04_STI Inspection Recommendations.pdf

NCBC Gulfport, MS 2021 Annual STI Report

NAVFAC SE Recommendations based on the STI annual inspection report

NAVFAC SE can provide vehicle to make any noted repairs if local resources are unavailable.

Water in Interstice - 186-01, 241-01, 385-01, 400-14

Recommend draining the water from the interstice. Recommend evaluating how water entered the interstice, introducing countermeasures to prevent future intrusion, and incorporating monthly inspection reports to ensure interstice is dry. This should be noted on the monthly inspection record.

Vents

a) Sub-standard emergency vents (non-UL) – 18-01, 32-03, 203-01, 217-01, 321-01, 329-01, 343-01, 361-01, 361-02, 435-02, 447-01, 449-01, 451-01, 452-01, 463-01, 465-01, 470-05

No action is required. The installed non-UL emergency vents are not considered deficient and this is being noted for information purposes for future consideration of replacement.

b) Normal vent, not installed (port available) – 400-09, 400-10, 400-11, 400-12, 400-13

Recommend installing a normal vent to meet the UL-142 Section 8 venting requirement.

c) Normal vent, reduced – 274-01

No action required. Normal vent is 2” reduced to a 1-1/4” port. This is sufficient venting because the tank has a loose fill, but if an OPV was installed, a 2” normal vent would need to be installed. Recommend not installing an OPV.

Tank bulging – 185-02

Bulging near the EVs. Recommend investigating the cause of the bulging and correcting if diagnosable. The vents were inspected to be satisfactory so it’s not likely an issue with undersized vents or the EV moving freely. May be the result of an old issue with the vents that has since been corrected.

Tank dented – 400-13

Minor dent in tank top near spill bucket. Tank is under a canopy in the 2016 SPCC plan. If this is still the case, the dent will not hold water and no action is required. Otherwise, recommend incorporating in the monthly inspections

(if not already incorporated), an inspection for water resting in the dent and immediate removal of water. This should be noted on the monthly inspection record.

Interstice leak detection

Where interstice gauges are not installed or not connected, recommend employing during the monthly inspections, a visual inspection of the interstice via sticking through an available port (or a broken interstice gauge port). This will meet the requirements for monitoring the interstice for leakage. This should be noted on monthly inspection record.

If desired, recommend installing an interstice gauge as a mechanism to monitor the interstice for leakage.

a) None installed (port available) – 182-01, 217-01, 241-01, 274-01, 276-01, 385-01, 397-01, 400-14, 400-15, 400-16, 400-18, 400-19, 416-01, 465-02

b) None installed (no port available) – 400-09, 400-10, 400-11, 400-12, 400-13, 400-17

c) Probe not connected – 322-01, 417-01, 435-02, 451-01

d) Alarm light inoperable – 18-01, 203-01, 329-01, 343-01, 447-03, 449-01, 452-01, 470-05

e) Rod too short – 465-03

Level gauge, inaccurate – 276-01, 385-01, 400-12, 400-13, 400-17, 451-01

The 40 CFR 112.8(c)(8) requirement for overfill prevention is met through (iv) “a fast response system for determining the liquid level for each tank, such as a direct vision gauge.” Recommend repairing or replacing the inaccurate liquid level gauges.

Automatic tank gauge (ATG), minor variance in measurement – 470-01, 470-02, 470-03, 470-04

No action required. Minor variance in measurement (<5%) between the ATG, level gauge, and dipstick for the liquid level.

Overfill prevention valve (OPV)

a) None installed (room to install) – 274-01, 416-01, 465-01

No action required. All of these tanks have liquid level gauges installed, which meets the 40 CFR

112.8(c)(8) requirement for overfill prevention. If desired to have an additional form of overfill prevention, an OPV may be installed.

b) Extra OPV installed – 185-02

Tank has two OPVs: one installed in the spill bucket and one installed outside of the spill bucket.

Recommend removing the OPV installed outside of the spill bucket and plugging the port so that the spill bucket is not bypassed.

c) Missing camlock – 185-02

OPV inside spill bucket does not have a camlock. Recommend removing the camlock from the OPV that is outside of the spill bucket to this OPV that is inside the spill bucket.

Spill bucket

a) None installed (room to install 7 gallon) – 324-01

Spill buckets provide secondary containment during filling. Recommend installing a spill bucket.

b) Holes – 400-15

The spill bucket cannot provide secondary containment if it has holes in it. Recommend replacing the damaged spill bucket.

Corrosion

Recommend removing corrosion prior to repainting surface to protect from possible containment failure in the future. NAVFAC SE can provide guidance on paint specs. If not already present, consider adding inspection to monthly inspection report for corrosion. This should be noted on monthly inspection record.

a) Moderate/Major corrosion- 18-01, 32-03, 182-01, 343-01, 361-02, 400-15, 435-02, 447-01, 465-01, 470-05

b) Minor corrosion – 32-02, 163-01, 203-01, 217-01, 241-01, 274-01, 321-01, 322-01, 329-01, 385-01, 400-

16, 400-17, 400-18, 400-19, 417-01, 447-03, 451-01, 470-01, 470-02, 470-03, 470-04

Debris on tank – 32-02, 163-01, 164-01, 186-01

Debris (grass, pine needles, etc.) around the tank and tank pad holds moisture and causes corrosion. Consider implementing SOP after grass is mowed to inspect and remove debris from the tank. Recommend incorporating in the monthly inspections (if not already incorporated), an inspection for debris around the tank and immediate removal of the debris. This should be noted on the monthly inspection record.

Standing water – 185-02, 321-01, 329-01, 361-02, 385-01, 400-15, 435-02, 449-01, 463-01, 465-01

Tank has standing water or evidence thereof. Monitor tanks after rainfall events. Consider implementing SOP after major rainfall events to inspect and remove any resting water on tank top. Recommend incorporating in the monthly inspections (if not already incorporated), an inspection for water resting on tank top and immediate removal of water. This should be noted on the monthly inspection record.

Grounding strap

NFPA 30 Section 6.5.4.2 requires all tanks to be grounded (to earth). Recommend installing or replacing grounding straps to tanks.

a) None installed – 32-02, 274-01, 276-01, 321-01, 322-01, 385-01, 397-01, 400-14, 400-16, 400-17, 447-03

b) Broken – 400-15

Low melting point materials – 241-01, 276-01, 397-01, 400-14, 400-15, 400-16, 400-17, 400-18

PVC, copper, and other low melting point materials are at risk of melting and exposing tank contents during a fire.

Recommend replacing these components with higher melting point materials (stainless steel, etc.).

Concrete pad, cracked – 447-03, 452-01

Recommend monitoring cracking as part of monthly inspection. Consider repairs of cracking with local resources.

Any major settling/sifting of the concrete pad shall be noted and evaluated for corrective actions.

Labels

Recommend installing the required signage and replacing the mislabeled/faded signage.

a) Fire diamond, missing/peeling – 163-01, 164-01, 165-01, 184-01, 186-01, 188-02, 276-01, 385-01, 398-03, 400-17, 417-01, 465-01

b) Contents, missing/peeling/unreadable – 164-01, 184-01, 186-01, 203-01, 276-01, 321-01, 385-01, 397-01, 398-03, 417-01, 435-02, 452-01

c) No smoking, missing/peeling/unreadable – 188-02, 276-01, 385-01, 400-09, 400-10, 400-11, 400-12, 400-

17, 400-19, 417-01, 435-02, 447-01, 465-01, 470-05

d) Tank ID, peeling – 276-01, 385-01, 397-01, 417-01, 452-01

e) Capacity, peeling – 276-01, 385-01, 397-01, 417-01, 452-01