Attachment J - Barksdale-Fac 6350-2 Final 2022.pdf

US Army Corps of Engineers Omaha District

API 653 Out‐of‐Service Inspection Report

Barksdale AFB, LA Tank 2 (Facility 6350‐2)

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

(USACE POL‐MCX)

12/13/2022

Table of Contents

ACRONYMS AND ABBREVIATIONS

GENERAL SUMMARY

INSPECTION DATE

PREVIOUS INSPECTION DATES

STATE REGULATIONS

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

A. GENERAL PROJECT INFORMATION

1. API 653 Inspection

2. Site Information

B. TANK INSPECTION COMMENTS

1. Tank Construction

2. Secondary Containment

3. Tank Foundation

4. Tank Bottom

5. Tank Shell

6. Tank Floating Roof

7. Tank Fixed Roof

8. Tank Appurtenances

9. Tank Piping System

10. Fire Protection System

C. FINDINGS AND RECOMMENDATIONS

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

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

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

APPENDIX A: ENGINEERING CALCULATIONS

APPENDIX B: ENGINEERING DRAWINGS

APPENDIX C: ENGINEERING DATA

APPENDIX D: API 653 CHECKLISTS FOR TANK INSPECTIONS

APPENDIX E: PHOTOGRAPHS

APPENDIX F: FOLLOW‐ON NDE\MODIFICATION REPORTS

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 Out‐of‐Service inspection of Tank 2 (Facility 6350‐2) at Barksdale AFB, LA was completed on December 13, 2022. The internal floating roof double wiper seals were replaced as part of this project. The tank service life evaluation performed as having greater than 30 years of remaining shell life under current conditions.

Significant Findings (overview)

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

1. None.

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

1. The 14‐inch issue line has a flange on the line side of the tank skin valve in which several of the bolts do not have adequate thread engagement with the nuts. The bolt threads must extend past the nut by at least one thread per ASME 31.3 Section 335.2.3. (Quantity: 8 bolts)

2. The 10‐inch receipt line has a flange on the tank side of the tank skin valve which all the bolts do not have adequate thread engagement with the nuts. The bolt threads must extend past the nut by at least one thread per ASME 31.3 Section 335.2.3. (Quantity: 8 bolts)

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

1. The edge of the bottom plate projection beyond the shell has failed coating and corrosion around the entire tank circumference. (Quantity: 110 LF)

2. The notch at the bottom and top of the vertical members of the anchor chairs are completely welded closed in lieu of leaving them open to clear the shell‐to‐bottom weld per AW 78‐24‐27 Drawing D.04 Detail 2. (Quantity: 12)

3. The tank ground straps are exothermically welded to a carbon steel ground lug in lieu of stainless steel and do not have mounting plates on the shell in accordance with AW 78‐24‐27 Drawing ED.02 Details 1 and 2. (Quantity: 4)

4. The shell overflow/circulation vents have carbon steel screens in lieu of corrosion resistant screens per AW 78‐24‐27. These shell overflow/circulation vents have minor coating failure with surface corrosion (Quantity: 4)

5. The SHAND&JURS mechanical tape level gauge (MTG) is broken. The MTG tape is piled on top of the floating roof. Base personnel removed the tape to prevent damage to the new floating roof seals prior to placing the tank back into service. Note: The ENRAF ATG system has a readout on the exterior berm wall. (Quantity: 1)

6. The shell supports of the mechanical tape level gauge (MTG) do not have reinforcement plates on the shell. (Quantity: 3)

7. The shell supports for the conduit on the north side of the tank do not have reinforcement plates on the shell. (Quantity: 7)

8. The shell supports for the conduit on the south side of the tank do not have reinforcement plates on the shell. (Quantity: 5)

9. The shell has unused supports without reinforcement plates on the shell. (Quantity: 9)

10. The water draw‐off line is 1‐inch welded carbon steel in lieu of 1‐inch welded and flanged stainless steel piping and flanges per AW 78‐24‐27 Drawing D.13 Detail 5. The water draw‐off system drains into a product recovery tank (PRT) by the pump house in lieu of a product saver tank (PST) at the tank per UFC

3‐460‐01 Section 8‐3.14.3, AW 78‐24‐27 Drawing G.05, and AW 78‐24‐27 Drawing D.13 Detail 5.

(Quantity: 1)

11. The reinforcement pad telltale hole of the 4‐inch low suction line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐ 03 Section 8‐9.13.4.1. (Quantity: 1)

12. The 4‐inch stripping line of the low suction line is housed with a 2‐inch threaded cap in lieu of a 4‐inch cam type connection with dust cover per AW 78‐24‐27 Drawing G.05. (Quantity: 1)

13. The thermal relief system for the low suction line and issue line has 3/4‐inch welded and threaded carbon steel piping in lieu of 1‐inch welded and flanged stainless steel piping and flanges and does not have test TEEs for routine testing of the thermal relief valves (TRVs) per UFS 3‐460‐03 and AW 78‐24‐27 Drawing D.10 Detail 4. (Quantity: 1 system; 2 TRVs)

14. The reinforcement pad telltale hole of the 14‐inch issue line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1. (Quantity: 1)

15. The reinforcement pad telltale hole of the 10‐inch receipt line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1. (Quantity: 1)

16. The tank does not have a high liquid level shut‐off valve with an upstream isolating double‐block and bleed plug valve per UFC 3‐460‐01 Table 8‐1 Item (bb), AW 78‐24‐27 Drawing G.05, and Drawing D.12 Details 2 and 3. (Quantity: 1)

17. The receipt line thermal relief system has a VISI‐FLOW sight glass indicator, which is not allowed per UFC 3‐460‐01 Sec. 9‐3.5.1. (Quantity: 1)

18. The thermal relief system for the receipt line has 3/4‐inch welded and threaded carbon steel piping in lieu of 1‐inch welded and flanged stainless steel piping and flanges, and does not have a flanged test TEE for routine testing of the thermal relief valve (TRV) per UFC 3‐460‐03 and AW 78‐24‐27 Drawing G.05 and Drawing D.10 Detail 4. (Quantity: 1 system)

19. The reinforcement pad telltale hole of both 36‐inch manways is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1. (Quantity: 1 ea.)

20. The cover of both 36‐inch manways in the first shell course does not have a filler drum installed to prevent damage to the floating roof seals when the floating roof operates in the low leg position. Note:

The tank normally operates the floating roof in the high leg position. (Quantity: 1 ea.)

21. The cover of both 36‐inch manways only has one handle in lieu of two (2) handles for safe opening per API Standard 650 Section 5.8.3.5 and AW 78‐24‐27 Drawing D.10 Detail 3. (Quantity: 1 ea.)

22. The cover of both 36‐inch manways has hinges in lieu of davit arms per AW 78‐24‐27 Drawing D.10 Detail 3. (Quantity: 1 ea.)

23. The tank does not have a 36‐inch upper manway with platform per UFC 3‐460‐01 Table 8‐1 Item (c), AW 78‐24‐27 Drawing D.11 Detail 1, and AW 78‐24‐27 Drawing D.10 Details 3 and 6. (Quantity: 1)

24. The tank does not have independent low and low‐low level alarms UFC 3‐460‐01 Table 8‐1 Item (l) and AW 78‐24‐27 Drawing D.12 Detail 1. (Quantity: 1)

25. The independent high level alarm (HLA) assembly is constructed from 1‐inch threaded carbon steel in lieu of welded and flanged stainless steel, has threaded shell nozzles with non‐lockable ball valves in lieu of flanged shell nozzles with lockable ball valves, does not have a means for routine testing, and does not have a 1‐inch drain line to a product saver tank (PST) for routine testing per AW 78‐24‐27 Drawing D.12 Detail 2. (Quantity: 1)

26. The tank does not have an independent high‐high level alarm per UFC 3‐460‐01 Table 8‐1 Item (l) and AW 78‐24‐27 Drawing D.12 Detail 2. (Quantity: 1)

27. The top shell course has two (2) 1‐inch threaded couplings with plugs next to the high level alarm assembly. (Quantity: 2)

28. The circumferential stairway has minor coating failure and corrosion. (Quantity: 200 SF)

29. The free‐standing circumferential stairway is carbon steel in lieu of galvanized, and the supports are welded directly to the shell in lieu of having lap‐welded support plates per AW 78‐24‐27 Drawing D.11 Details 1‐4. (Quantity: 1 stairway; 2 platforms)

30. The circumferential stairway platform at the high level alarm does not have uniform step rise and run with the upper step and bottom step of the platform. (Quantity: 1 step ea.)

31. The fixed roof has standing water at the edge of the roof perimeter. Standing water will reduce the service life of the coating system. (Quantity: 10 areas)

32. The fixed roof has a 12‐inch center roof vent in lieu of 24‐inch vent per AW 78‐24‐27 Drawing D.09 Detail 2. (Quantity: 1)

33. The fixed roof is not equipped with two 6‐inch Ø reinforced scaffold cable supports within 6‐feet of the center roof vent per AW 78‐24‐27 Drawing 5.02 Item V and API Standard 650 Figure 5.22. (Quantity: 2)

34. The fixed roof circulation vents/inspection hatches are carbon steel welded to the roof in lieu of being hinged stainless steel per AW 78‐24‐27 Drawing D.09 Detail 1. The intermediate rail of the roof perimeter handrail at these vents has carbon steel pipe in lieu of galvanized chain per AW 78‐24‐27 Drawing D.09 Detail 1 and Drawing D.11 Detail 5. The vents have a 6‐inch by 10‐inch inspection hatch on the vent. The inspection hatches are secured shut by a thin carbon steel chain. The chains are heavily corroded and are too short to allow easy opening. Two of the ports cannot be opened due to the chains being too short. (Quantity: 4)

35. The access hatch for internal ladder on the fixed roof has an obsolete 8‐inch sample hatch that was replaced with a dedicated sample gauge. (Quantity: 1)

36. The bottom appears to have never been coated under the floating roof support legs when the stainless steel bearing plates were removed in 2011. These locations do not show any signs of corrosion.

(Quantity: 7 legs)

37. A lap‐welded pipe support pad for the receipt line diffuser does not have the required weld spacing of 2 inches between the pad and bottom lap‐weld as required by API standards. Magnetic particle (MT) examination is required on the affected welds, if not repaired. Note: MT testing might be required on all future inspections until modified. (Quantity: 1 area)

38. The receipt line diffuser inside the tank is carbon steel in lieu of stainless steel and has one pipe support in lieu of 2 supports per AW 78‐24‐27 Drawing D.08 Details 1 and 6. (Quantity: 1 new support)

39. The pipe support for the receipt line diffuser inside the tank is not adjustable and does not have a TEFLON coated U‐Bolt per AW 78‐24‐27 Drawing D.08 Details 1 and 6. (Quantity: 1 existing support)

40. The 14‐inch issue line inside the tank is carbon steel in lieu of stainless steel, the diameter of the anti‐ vortex plate is not at least 28‐inches, and has one pipe support in lieu of 2 supports per AW 78‐24‐27 Drawing D.08 Details 4 and 6. (Quantity: 1 new anti‐vortex plate; 1 new support)

41. The pipe support for the issue line inside the tank is not adjustable and does not have a TEFLON coated U‐Bolt per AW 78‐24‐27 Drawing D.08 Details 4 and 6. (Quantity: 1 existing support)

42. The pipe supports for the low suction line and water draw‐off line inside the tank are not adjustable and do not have TEFLON coated U‐Bolts per AW 78‐24‐27 Drawing D.08 Detail 6. (Quantity: 2 supports)

43. The lap‐welded bearing plate of the floating roof anti‐rotation anchor has square corners in lieu of rounded corners and does not meet the minimum dimensions required by API Standard 653 Sections 9.10.1.1.b and 9.10.3, and Figure 9.13. (Quantity: 1)

44. The floating roof has one anti‐rotation device in lieu of 2 anti‐rotation devices. The internal floating roof shall not depend solely on the peripheral seals or vertical penetration wells to maintain the centered position or to resist rotation per API Standard 650 Section H.5.4. (ref. API Standard 650 Section H.5.4, API Standard 653 Sections 9.10.1.1.b and 9.10.3, and Figure 9.13) (Quantity: 1 new)

45. The VITO stilling well consists of a 4‐inch aluminum steel in lieu of a 6‐inch stilling well and the lower portion is slotted in lieu of slotted to within 6‐inches of the shell overflow ports per AW 78‐24‐27 Drawing D.07 Detail 3. (Quantity: 1)

46. The base of the sample gauge 8‐inch aluminum slotted stilling well does not conform to AW 78‐24‐27 Drawing D.07 Detail 2. The stilling well is bolted to the bottom and flanged at the fixed roof, which prevents adequate movement. Base personnel removed the bolts at the bottom to allow adequate movement. (Quantity: 1)

INSPECTION DATE

API Out‐of‐Service Inspection Date: December 13, 2022 Equipment Used: Ultra‐Sonic Thickness Meter Manufacturer: General Electric Model: DMS 2 Calibration Methods Used: Zeroing Procedure, Copper Coating Calibration

Procedure, and Two Point Calibration Procedure Inspector(s): Wayne K. Bailey API 653 Inspector No. 1331

Equipment Used: Surveying Tool Manufacturer: Leica Model: 3D DISTO Calibration Methods Used: Manufacturer Inspector(s): Wayne K. Bailey API 653 Inspector No. 1331

Equipment Used: MFL Floor Scanner Manufacturer: MFE Enterprises Model: Mark IV Calibration Methods Used: Sensitivity adjacent on manufacturer supplied test plate with simulated anomalies and notch

PREVIOUS INSPECTION DATES

API Out‐of‐Service (Internal) Inspection Date: November 2011 API In‐Service (External) Inspection Date: July 2017

STATE REGULATIONS

State Regulation for API In‐Service Tank Inspections: NA State Regulation for API Out‐of‐Service Tank Inspections: NA

RECOMMENDED FUTURE INSPECTION DATES (CALCULATIONS SHALL BE PROVIDED)

API Out‐of‐Service (Internal) Inspection Date: December 2042* API In‐Service (External) Inspection Date: December 2027

* Not to exceed 10 years at time of inadequate protection from the ICCP system.

Wayne K. Bailey, API‐653 #1331

GENERAL TANK INFORMATION

ITEM DESCRIPTION

Owner US Air Force Location Barksdale AFB Facility Number 6350‐2 Tank Number 2 State / Country Louisiana, United States City Bossier City Inspection Date December 13, 2022 Tank Manufacturer Woods Tank Inc.

Design Standard API Standard 650, 9th Edition Date of Construction 1998 Tank Contents Jet‐A (F‐24) Tank Serial Number 6350‐2 Tank Diameter 32’ 9‐1/2” Shell Height 39’ 4” Overflow Height 35’ 8” (by sample gauge) Safe Fill Height 33' 6" (by sample gauge) Tank Capacity 4,400 barrels Foundation Elevated Concrete Ringwall

Construction

Bottom Lap‐Welded, cone down Shell Butt‐Welded (Cylindrical) Floating Roof Flat Aluminum Honeycomb IFR Fixed Roof Fasteners

Material

Bottom Carbon Steel, A‐36 Shell Carbon Steel, A‐36 Floating Roof Aluminum, Unknown Grade Fixed Roof Carbon Steel, A‐36

Cathodic Protection Impressed Current Cathodic Protection (ICCP) System Interior Coating System Thin Film Epoxy (assumed) Exterior Coating System Thin Film Epoxy/Polyurethane (assumed) Level Gauging ENRAF ATG, VITO ATG, and Shand & Jurs MTG Overfill Protection None

Piping

Receipt 10" Carbon Steel Issue 14" Carbon Steel Low Suction 4” Carbon Steel Water Draw‐Off 1" Carbon Steel

Level Alarms & Controls

Description ENRAF ATG Independent (Shell) High‐High Level Alarm: Unknown None High‐Level Alarm: Unknown 34’ 1” Low‐Level Alarm: Unknown None Low‐Low Level Alarm: Unknown None High‐Level Control Shut‐off: None

Type of Internal Floating Roof 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 Out‐of‐Service inspection was performed for Tank 2 (Facility 6350‐2).

2. Site Information On December 13, 2022, InterSpec, LLC performed an API 653 Out‐of‐Service inspection of Tank 2 (Facility 6350‐2), located at Barksdale AFB, LA.

B. TANK INSPECTION COMMENTS

1. Tank Construction Tank 2 is a nominal 4,400 barrels, 32’ 9‐1/2” diameter by 39’ 4” tall, Jet‐A, aboveground vertical storage tank. The original construction data plate was affixed above the manway. The tank was field erected in 1998. The tank was upgraded in 2011 by CAPE Environmental, Inc for new stilling wells, bottom coating, along with other miscellaneous repairs. The 2011 repair data plate was affixed above the manway adjacent to the original construction nameplate. The internal floating roof double wiper seals and penetrations seals were replaced during this inspection.

2. Secondary Containment 40 CFR 112.7(c) states that the entire secondary containment system, “including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system ... will not escape containment before cleanup occurs.” 40 CFR 112.8(c)(2) and 40 CFR 112.12(c)(2) state that diked areas must be “sufficiently impervious to contain oil.” The purpose of the secondary containment requirement is to prevent discharges, as described in 40 CFR 112.1(b); therefore, effective secondary containment methods must be able to contain oil until the oil is cleaned up. The secondary containment area consists of a polyurea coated concrete floor and vertical walls. An informal containment evaluation was conducted. The containment appears to be of sufficient size to contain a total tank loss per UFC 3‐460‐01 Section 8‐14.2.1, “The containment area needs to have sufficient capacity to contain the tank contents plus one foot of freeboard. If the containment has the capacity to contain the tank contents plus one foot of freeboard, the containment area is sufficient.” The secondary containment capacity is sufficient with at least one foot of freeboard. The secondary containment area is properly graded to drain water away from the tank and piping in accordance with NFPA 30. The secondary containment drain was hydrostatically tested and is in satisfactory condition.

3. Tank Foundation The tank rests on an elevated concrete ringwall. The tank has an impressed current cathodic protection (ICCP) system installed. Base personnel stated that the anode bed for the ICCP system is approaching its end of life. The tank has bottom leak detection telltale drains; it is in satisfactory condition. The foundation was visually evaluated during the inspection for broken concrete, spalling, cracks, and vegetation against the bottom of the tank; it is in satisfactory condition. The tank bottom‐to‐ringwall sealant was inspected; it is in satisfactory condition. A shell settlement survey was performed during the inspection in accordance with Appendix B of API Standard 653; it is in satisfactory condition. Settlement results are listed in Appendix A.

4. Tank Bottom The bottom is a cone‐down configuration with rectangular shaped lap‐welded carbon steel plates that is fillet‐welded to the shell. The bottom has a thin film epoxy coating system (assumed). The coating system was inspected for disbonding, adhesion, deterioration, and discoloration; it is in satisfactory condition. The bottom was scanned (approximately 95%) for underside corrosion using magnetic flux leakage (MFL) technology. The MFE 2412 Mark II unit was used for the MFL floor scan. The MFL scan did not reveal any areas of underside corrosion. The bottom has no significant stockside (top side) pitting. The general thickness of each bottom plate was measured using ultrasonic technology. The general thickness measurements and associated thickness measurement locations (TML) are listed in the Bottom Plate Thickness Measurements table in Appendix C. The bottom is equipped with a circular 36‐inch sump having a depth of 10 inches located in the center of the floor. The general thickness of the sump was measured using ultrasonic technology; it is in satisfactory condition. The bottom plate welds, shell‐to‐bottom weld, attachment welds, piping supports, and support pads were visually examined and appear to be in satisfactory condition. The visual examination of the welds for defects was limited because the welds are coated. One lap‐ welded pipe support pad for the receipt line diffuser does not have the required weld spacing of 2 inches as required by API standards. The bottom service life evaluation shows the out‐of‐ service interval of operation (years to next internal inspection) to be greater than 30 years under current conditions. The bottom service life evaluation is shown in Appendix A. The bottom service life evaluation is based on the ICCP system affording continuous adequate protection.

5. Tank Shell The shell is constructed of carbon steel material. The shell is a cylindrical design, butt‐welded together, consisting of five (5) courses. The shell exterior and interior have a thin film epoxy coating system (assumed). The coating was inspected for disbonding, adhesion, deterioration, and discoloration; it is in satisfactory condition. The shell was evaluated for remaining metal thickness utilizing ultrasonic technology. The ultrasonic thickness measurements and thickness measurement locations (TML) are listed in the Shell Plate Thickness Measurements table in Appendix A. A shell service life evaluation performed on all shell courses shows the shell has a remaining life of greater than 30 years under current conditions. The shell service life evaluation is shown in the Shell Service Life Evaluation table in Appendix A. Roundness, plumbness, peaking, and banding of the shell are all within the allowable tolerances of API Standard 653. The tank is anchored via anchor chairs. The tank appears to be stable and does not appear to be in danger of overturning or buckling due to high winds or seismic conditions.

6. Tank Floating Roof The tank is equipped with an internal full surface contact aluminum honeycomb design that is fitted with peripheral primary and secondary wiper perimeter seals. The floating roof support legs are fitted with PTFE feet per UFGS 33 56 21.17 Section 2.13.2.6. The peripheral double wiper seals and all IFR penetration seals were replaced during this inspection.

7. Tank Fixed Roof The fixed roof is an I‐beam span supported cone roof design 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; it 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 C.

8. Tank Appurtenances Note: The following table is an overview of the appurtenance status regarding UFC‐3‐460‐01 and AW 78‐24‐78 standards and does not reflect API standards, federal regulations, state regulations, and/or local regulations.

Overview of Appurtenance

Item Appurtenance

Installed Fully or Partially

Meets Current Design

Standards A. Manhole

1. 36‐inch manhole located above the IFR high leg position. ☐ ☐

2. At least two (2) fixed roof manholes. ☐ ☐

3. At least two (2) 36‐inch shell manholes. ☒ ☐

4. A bolted cover in the fixed roof for installation of IFR. ☒ ☒ B. Inspection Hatches

1. At least of four (4) 24‐inch square inspection hatches on fixed roof with IFR (min. spacing 32 feet).

C. Ladder/Stairs

1. Internal ladders with internal floating roofs. ☒ ☒

2. Access to high level shut‐off and alarms. ☒ ☐ D. Level Alarms An individual automatic level alarm system, independent of the gauging device or system. Include high, high‐high, low and low‐ low level alarms. On aboveground tanks: provide a means to manually test each alarm sensor to ensure system operability without a full tank; locate level alarm equipment for ready access from ground level, stairway platforms, or roof access.

Overview of Appurtenance

Item Appurtenance

Installed Fully or Partially

Meets Current Design

Standards

1. High‐High Level Alarm ☐ ☐

2. High Level Alarm ☒ ☐

3. Low Level Alarm ☐ ☐

4. Low‐Low Level Alarm ☐ ☐ E. Vents

1. Open atmospheric vents with weather hoods and bird screens. ☒ ☐

2. Emergency relief venting (a floating roof or frangible joint may be used to fulfill emergency relief requirements).

F. Gauge/Gauge Hatch/Stilling Wells

1. A mechanical liquid level gauge. ☒ ☐

2. Automatic Tank Gauging (ATG) (ENRAF fuel level & VITO water level systems).

3. One 10‐inch roof flanged nozzle with an 8‐inch aluminum, fully slotted, stilling well for ATG near the edge of the roof near the top of the stairway platform for fuel level ATG.

4. One 8‐inch roof flanged nozzle with a 6‐inch aluminum, fully slotted, stilling well for temperature and water bottom sensor, as close to or in the tank sump as possible for water level ATG.

5. One 10‐inch roof nozzle and an aluminum, slotted stilling well for gauging and sampling.

G. Piping Connection

1. Receipt Line ☒ ☐

2. Low Suction Line ☒ ☐

3. Issue Line. ☒ ☐ H. Overfill Protection

1. Overfill protection with a hydraulically operated diaphragm control valve.

I. Water Draw‐Off

1. Water draw‐off system. ☒ ☐ J. Ball Joints

1. Ball joints on pipes to relieve strain caused by tank settling or seismic activity or other means.

K. Cable Supports

1. On the fixed roof of all tanks, provide two scaffold cable supports

a. Water Draw‐Off System

1) Water Draw‐Off Line: The piping is 1‐inch welded carbon steel piping. The system has a 2‐ inch double‐block and bleed plug valve at the shell.

2) Product Saver Tank: The tank does not have a product saver tank (PST). The water draw‐off line discharges directly into a product recovery tank.

b. Low Suction System

The tank is equipped with a 4‐inch carbon steel low suction line. The low suction line is tied into the issue line.

c. Issue Line The 14‐inch issue line is carbon steel. The line is protected from overpressure with a thermal relief system.

d. Receipt Line The 10‐inch receipt line is carbon steel. The line is protected from overpressure with a thermal relief system. The thermal relief system consists of 3/4‐inch welded carbon steel piping and fittings. The issue line does not have a high liquid level shut‐off control valve.

e. Automatic Tank Gauging (Fuel Level) The tank is equipped with a ENRAF system for electronic fuel level gauging. The system is installed in an 8‐inch slotted aluminum steel stilling well.

f. Automatic Tank Gauging (Water Level) The tank is equipped with a VITO system for electronic water level gauging. The system is installed in a 4‐inch aluminum steel stilling well near the sump. The stilling well is not slotted at the bottom.

g. Mechanical Tank Gauging The tank is equipped with a SHAND&JURS mechanical tape level gauge for mechanical fuel level gauging. The mechanical tape level gauge is broken. Base personnel removed the tape to prevent damage to the newly installed floating roof seals.

h. Tank Sampling\Manual Gauging The tank is equipped with a separate 8‐inch slotted aluminum steel stilling well for sampling and manual gauging.

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

The high level alarm assembly is accessible from a platform on the circumferential stairway.

The piping consists of 1‐inch threaded carbon steel piping and fittings and does not have a means for routine testing.

j. Ladder and Platforms The tank’s fixed roof is accessible by a free‐standing carbon steel circumferential stairway. The circumferential stairway has platforms at the high level alarm assembly and top of the shell.

The floating roof is accessible by in internal ladder from the fixed roof.

k. Grounding The tank has four (4) grounding straps around the circumference of the tank.

l. Anchoring The tank has anchor chairs for anchoring.

9. Tank Piping System The pumphouse receives fuel from trucks. Fuel is issued to bulk storage.

10. Fire Protection System There are two fire hydrants within 300 feet of the tank.

C. FINDINGS AND RECOMMENDATIONS

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

1. MANDATORY REPAIRS per API 653, UFC 3‐460‐01, or AW 78‐24‐27 Standards Mandatory repairs represent items that require immediate attention, in order to prevent imminent risk to system operators, equipment integrity, or the adjacent environment. The tank should remain out of service until these repairs are completed.

a. None

2. REQUIRED REPAIRS to Fully Comply with API 653, or, Federal, State, and Local Codes Recommended repairs represent items that should be addressed in a timely manner, in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment. These items may be required by federal, state and local codes, or by military criteria.

a. Improper Thread Engagement on Issue Line OBSERVATION: The 14‐inch issue line has a flange on the line side of the tank skin valve in which several of the bolts do not have adequate thread engagement with the nuts. The bolt threads must extend past the nut by at least one thread per ASME 31.3 Section 335.2.3.

CODE REFERENCE: ASME 31.3 Section 335.2.3 RECOMMENDATION: Replace the hardware on the 14‐inch issue line to meet the requirements of ASME 31.3. (Quantity: 8 Bolts)

b. Improper Thread Engagement on Receipt Line OBSERVATION: The 10‐inch receipt line has a flange on the tank side of the tank skin valve which all the bolts do not have adequate thread engagement with the nuts. The bolt threads must extend past the nut by at least one thread per ASME 31.3 Section 335.2.3.

CODE REFERENCE: ASME 31.3 Section 335.2.3 RECOMMENDATION: Replace the hardware on the 10‐inch receipt line to meet the requirements of ASME 31.3. (Quantity: 8 Bolts)

3. RECOMMENDED REPAIRS TO FULLY COMPLY WITH UFC 3‐460‐01, AW 78‐24‐27 Standards or as Part of Regular Maintenance Recommended repairs represent items that should be addressed in a timely manner, in order to prevent future potential risks to system operators, equipment integrity, or the adjacent environment.

a. Coating Failure on Bottom Projection OBSERVATION: The edge of the bottom plate projection beyond the shell has failed coating and corrosion around the entire tank circumference.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐3.1 and UFGS 09 97 13.27 RECOMMENDATION: Mechanically clean and recoat the bottom projection beyond the shell in accordance with UFGS 09 97 13.27. (Quantity: 110 LF)

b. Anchor Chair Configuration OBSERVATION: The notch at the bottom of the vertical members of the anchor chairs are completely welded closed in lieu of leaving them open to clear the shell‐to‐bottom weld per AW 78‐24‐27 Drawing D.04 Detail 2.

CODE REFERENCE: AW 78‐24‐27 Drawing D.04 Detail 2 RECOMMENDATION: Reconfigure the anchor chairs to meet the criteria described in AW 78‐24‐27 Drawing D.04. (Quantity: 12)

c. Tank Grounding OBSERVATION: The ground straps are bolted to a coated grounding lug on the shell. Ground straps exothermically welded to stainless grounding lugs with reinforcement pads on the shell are recommended in accordance with AW 78‐24‐27 Drawing ED.02 Details 1 and 2.

CODE REFERENCE: AW 78‐24‐27 Drawing ED.02 Details 1 and 2.

RECOMMENDATION: Install a stainless steel ground lug and carbon steel pad on shell for the ground straps and exothermically weld the grounding cable to the ground lug in accordance with AW 78‐24‐ 27 Drawing ED.02 Details 1 and 2. (Quantity: 4)

d. Shell Overflow/Circulation Vent Corrosion OBSERVATION: The shell overflow/circulation vents have carbon steel screens in lieu of corrosion resistant screens per AW 78‐24‐27 Drawing D.07 Detail 6. These shell overflow/circulation vents have minor coating failure with surface corrosion.

CODE REFERENCE: AW 78‐24‐27 Drawing D.07 Detail 6, UFC 3‐460‐03 Section 6‐1.5 (a), and UFGS 09 97 13.27.

RECOMMENDATION: Replace the shell overflow/circulation vents screens with corrosion resistant screens per AW 78‐24‐27 Drawing D.07 Detail 6. Mechanically clean and recoat the shell overflow/circulation vents in accordance with UFGS 09 97 13.27. (Quantity: 4)

e. Broken Mechanical Tape Level Gauge OBSERVATION: The SHAND&JURS mechanical tape level gauge (MTG) is broken. The MTG tape is piled on top of the floating roof. Base personnel removed the tape to prevent damage to the new floating roof seals prior to placing the tank back into service. Note: The ENRAF ATG system has a readout on the exterior berm wall.

CODE REFERENCE: UFC 3‐460‐01 Table 8‐1(q); AW 78‐24‐27 Drawing D.07 Detail 1.

RECOMMENDATION: Recondition the mechanical tape level gauge in accordance with manufacturer’s recommendations and UFC 3‐460‐01, if not removed. (Quantity: 1 System)

f. Mechanical Tape Level Gauge Shell Supports OBSERVATION: The shell supports of the mechanical tape level gauge (MTG) do not have reinforcement plates on the shell.

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

RECOMMENDATION: Install reinforcement plates on the shell for the mechanical tape level gauge supports in accordance with AW 78‐24‐27 Drawing D.07 Detail 1, if not removed. (Quantity: 3 Supports)

g. Conduit Shell Attachments on North Side of Tank OBSERVATION: The shell supports for the conduit on the north side of the tank do not have reinforcement plates on the shell.

CODE REFERENCE: AW 78‐24‐27 Drawing D.10 Detail 5 RECOMMENDATION: Install reinforcement plates on the conduit supports on the north side in accordance with AW 78‐24‐27 Drawing D.10 Detail 5. (Quantity: 7 Supports)

h. Conduit Shell Attachments on South Side of Tank OBSERVATION: The shell supports for the conduit on the south side of the tank do not have reinforcement plates on the shell.

CODE REFERENCE: AW 78‐24‐27 Drawing D.10 Detail 5 RECOMMENDATION: Install reinforcement plates on the conduit supports on the south side in accordance with AW 78‐24‐27 Drawing D.10 Detail 5. (Quantity: 5 Supports)

i. Unused Shell Supports OBSERVATION: The shell has unused supports without reinforcement plates on the shell.

CODE REFERENCE: General Maintenance / Good Engineering Practice RECOMMENDATION: Remove the unused shell supports from the tank. (Quantity: 9 Supports)

j. Water Draw‐Off Line Configuration OBSERVATION: The water draw‐off line is 1‐inch welded carbon steel in lieu of 1‐inch welded and flanged stainless steel piping and flanges per AW 78‐24‐27 Drawing D.13 Detail 5. The water draw‐ off system drains into a product recovery tank (PRT) by the pump house in lieu of a product saver tank (PST) at the tank per UFC 3‐460‐01 Section 8‐3.14.3, AW 78‐24‐27 Drawing G.05, and AW 78‐ 24‐27 Drawing D.13 Detail 5.

CODE REFERENCE: AW 78‐24‐27 Drawing D.13 Detail 5.

RECOMMENDATION: Replace the 1‐inch shell nozzle with a 2‐inch nozzle and install a second 2‐inch return line nozzle per AW 78‐24‐27 Drawing D.13 Detail 5. Furnish and install new two internal and external 2‐inch eccentric flat‐on‐bottom reducers and 2‐inch double‐block and bleed plug valve for each shell nozzle per AW 78‐24‐27 Drawing D.13 Detail 5. Reconfigure the welded and flanged stainless steel piping per AW 78‐24‐27 Drawing D.13 Detail 5. (Quantity: 1)

k. Low Suction Reinforcement Repad Telltale Hole OBSERVATION: The reinforcement pad telltale hole of the 4‐inch low suction line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐9.13.4.1.

RECOMMENDATION: Provide white lithium grease in the telltale hole of the low suction line’s reinforcement plate to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐

9.13.4.1. (Quantity: 1)

l. Low Suction Line Configuration OBSERVATION: The 4‐inch stripping line of the low suction line is housed with a 2‐inch threaded cap in lieu of a 4‐inch cam type connection with dust cover per AW 78‐24‐27 Drawing G.05.

CODE REFERENCE: UFC 3‐460‐01 Section 3‐6(i); AW 78‐24‐27 Drawing G.05; AW 78‐24‐27 Drawing D.02 RECOMMENDATION: Replace the 2‐inch threaded cap with a 4‐inch cam type connection with dust cover on the low suction line per AW 78‐24‐27 Drawing G.05. (Quantity: 1)

m. Thermal relief System for Low Suction and Issue Line OBSERVATION: The thermal relief system for the low suction line and issue line has 3/4‐inch welded and threaded carbon steel piping in lieu of 1‐inch welded and flanged stainless steel piping and flanges and does not have test TEEs for routine testing of the thermal relief valves (TRVs) per UFS 3‐ 460‐03 and AW 78‐24‐27 Drawing D.10 Detail 4.

CODE REFERENCE: UFC 3‐460‐01 Section 9‐3.5.1, AW 78‐24‐27 Drawing D.10 Detail 4 RECOMMENDATION: Replace the thermal relief system for the low suction and issue line per AW 78‐24‐27 Drawing D.10 Detail 4. (Quantity: 1 system; 2 TRVs)

n. Issue line Reinforcement Repad Telltale Hole OBSERVATION: The reinforcement pad telltale hole of the 14‐inch issue line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐9.13.4.1.

RECOMMENDATION: Provide white lithium grease in the telltale hole of the issue line’s reinforcement plate to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1.

o. Receipt line Reinforcement Repad Telltale Hole OBSERVATION: The reinforcement pad telltale hole of the 10‐inch receipt line is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐9.13.4.1.

RECOMMENDATION: Provide white lithium grease in the telltale hole of the receipt line’s reinforcement plate to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐

9.13.4.1. (Quantity: 1)

p. Receipt line Configuration OBSERVATION: The tank does not have a high liquid hydraulically operated diaphragm control valve with an upstream isolating double‐block and bleed plug valve per UFC 3‐460‐01 Table 8‐1 Item (bb), AW 78‐24‐27 Drawing G.05, and Drawing D.12 Details 2 and 3.

CODE REFERENCE: AW 78‐24‐27 Drawing D.12 Detail 2 and 3; UFC 3‐460‐01 Table 8‐1(bb) RECOMMENDATION: Reconfigure the 10‐inch receipt line to meet the criteria described in AW 78‐24‐ 27 Drawing D.12 Detail 2 and 3. (Quantity: 1 system)

q. Sight Flow Indicator on Receipt Line Thermal Relief Line OBSERVATION: The receipt line thermal relief system has a VISI‐FLOW sight glass indicator, which is not allowed per UFC 3‐460‐01 Sec. 9‐3.5.1.

CODE REFERENCE: UFC 3‐460‐01 Section 9‐3.5.1, AW 78‐24‐27 Drawing D.10 Detail 4 RECOMMENDATION: Remove the sight flow indicator from the product receipt’s thermal relief line.

(Quantity: 1 system)

r. Receipt Line Thermal Relief Line OBSERVATION: The thermal relief system for the receipt line has 3/4‐inch welded and threaded carbon steel piping in lieu of 1‐inch welded and flanged stainless steel piping and flanges and does not have a flanged test TEE for routine testing of the thermal relief valve (TRV) per UFC 3‐460‐03 and AW 78‐24‐27 Drawing G.05 and Drawing D.10 Detail 4.

CODE REFERENCE: UFC 3‐460‐01 Section 9‐3.5.1, AW 78‐24‐27 Drawing G.05 and Drawing D.10 Detail RECOMMENDATION: Replace the thermal relief system for the receipt line per AW 78‐24‐27 Drawing G.05 and Drawing D.10 Detail 4. (Quantity: 1 system)

s. Manway Reinforcement Plate Telltale Hole OBSERVATION: The reinforcement pad telltale hole of both 36‐inch manways is open to atmosphere with corrosion in lieu of being packed with white grease to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐9.13.4.1.

RECOMMENDATION: Provide white lithium grease in the telltale hole of both 36‐inch manways to prevent insect nesting and buildup of debris per UFC 3‐460‐03 Section 8‐9.13.4.1. (Quantity: 2)

Manway 1 Manway 1

t. Shell Manway Cover Filler Drum OBSERVATION: The cover of both 36‐inch manways in the first shell course does not have a filler drum installed to prevent damage to the floating roof seals when the floating roof operates in the low leg position. Note: The tank normally operates the floating roof in the high leg position.

CODE REFERENCE: AW 78‐24‐27 Drawing D.10 Detail 6.

RECOMMENDATION: Install a filler drum on the shell manway covers per AW 78‐24‐27 Drawing D.10 Detail 6. (Quantity: 2)

Manway 1 Manway 2

u. Shell Manway Cover Handles OBSERVATION: The cover of both 36‐inch manways only has one handle in lieu of two (2) handles for safe opening per API Standard 650 Section 5.8.3.5 and AW 78‐24‐27 Drawing D.10 Detail 3.

CODE REFERENCE: API Standard 650 Section 5.8.3.5 and AW 78‐24‐27 Drawing D.10 Detail 3.

RECOMMENDATION: Install an additional handle on the shell manway covers in accordance with AW 78‐24‐27 Drawing D.10 Detail 3. (Quantity: 2)

v. Shell Manway Cover Davit Arm OBSERVATION: The cover of both 36‐inch manways has hinges in lieu of davit arms per AW 78‐24‐27 Drawing D.10 Detail 3.

CODE REFERENCE: AW 78‐24‐27 Drawing D.10 Detail 3.

RECOMMENDATION: Replace the hinges with a davit arm on the shell manway covers in accordance with AW 78‐24‐27 Drawing D.10 Detail 3. (Quantity: 2)

w. Upper Shell Manway OBSERVATION: The tank does not have a 36‐inch upper manway with platform per UFC 3‐460‐01 Table 8‐1 Item (c), AW 78‐24‐27 Drawing D.11 Detail 1, and AW 78‐24‐27 Drawing D.10 Details 3 and 6.

CODE REFERENCE: AW 78‐24‐27 Drawing D.10 Detail 3 & 6; UFC 3‐460‐01 Table 8‐1(c) RECOMMENDATION: Install an upper shell manhole and reconfigure the circumferential stairway to meet the criteria described in AW 78‐24‐27. (Quantity: 1 manhole and intermediate platform for the stairway)

x. Independent Low and Low‐Low Level Alarm OBSERVATION: The tank does not have independent low and low‐low level alarms UFC 3‐460‐01 Table 8‐1 Item (l) and AW 78‐24‐27 Drawing D.12 Detail 1.

CODE REFERENCE: UFC 3‐460‐01 Table 8‐1(l); AW 78‐24‐27 Drawing D12 Detail 1.

RECOMMENDATION: Provide an independent low and low‐low level alarm system in accordance with UFC 3‐460‐01 Table 8‐1(l); AW 78‐24‐27 Drawing D12 Detail 1. (Quantity: 2 Alarms, 1 system)

y. Independent High Level Alarm (HLA) Assembly Configuration OBSERVATION: The independent high level alarm (HLA) assembly is constructed from 1‐inch threaded welded carbon steel in lieu of welded and flanged stainless steel, has threaded shell nozzles with non‐lockable ball valves in lieu of flanged shell nozzles with lockable ball valves, high and high‐high level alarms are not integrated into one assembly, are not integrated with the high liquid level shut‐off (HLSO) control valve assembly, and does not have a 1‐inch drain line to the product saver tank (PST) for routine testing per AW 78‐24‐27 Drawing D.12 Detail 2.

CODE REFERENCE: AW 78‐24‐27 Drawing D.12 Detail 2.

RECOMMENDATION: Reconfigure the independent high level alarm assembly to meet the criteria described in AW 78‐24‐27 Drawing D.12 Detail 2. (Quantity: 1)

z. High‐High Level Alarm OBSERVATION: The tank does not have an independent high‐high level alarm per UFC 3‐460‐01 Table 8‐1 Item (l) and AW 78‐24‐27 Drawing D.12 Detail 2.

CODE REFERENCE: AW 78‐24‐27 Drawing D.12 Detail 2; UFC 3‐460‐01 Table 8‐1 Item (l).

RECOMMENDATION: Provide an independent high‐high level alarm in accordance with AW 78‐24‐27 Drawing D.12 Detail 2. (Quantity: 1)

aa. Plugged Threaded Couplings in Upper Shell Course OBSERVATION: The top shell course has two (2) 1‐inch threaded couplings with plugs next to the high level alarm assembly.

CODE REFERENCE: API Standard 653 Section 9.3 and Figure 9.1.

RECOMMENDATION: Remove the plugged 1‐inch threaded shell couplings in the upper shell course adjacent to the high level alarm assembly and install lap‐welded patch plates per API Standard 653 Section 9.3 and Figure 9.1. (Quantity: 2)

bb. Coating Failure on Circumferential Stairway OBSERVATION: The circumferential stairway has minor coating failure and corrosion.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐3.1 and UFGS 09 97 13.27 RECOMMENDATION: Mechanically clean and recoat the circumferential stairway in accordance with UFGS 09 97 13.27. (Quantity: 200 SF)

cc. Circumferential Stairway Design OBSERVATION: The free‐standing circumferential stairway is carbon steel in lieu of galvanized, and the supports are welded directly to the shell in lieu of having lap‐welded support plates per AW 78‐ 24‐27 Drawing D.11 Details 1‐4.

CODE REFERENCE: AW 78‐24‐27 Drawing D.11 Details 1‐4.

RECOMMENDATION: Replace the circumferential stairway to include a ¼‐inch thick steel stringer plate with 4‐inch offset from the tank shell, level platforms, and replaceable galvanized bolt‐on step treads per AW 78‐24‐27 Drawing D.11 Details 1‐4. (Quantity: 1 stairway; 2 platforms)

dd. Circumferential Stair Treads Leading to/from Intermediate Platform OBSERVATION: The circumferential stairway platform at the high level alarm does not have uniform step rise and run with the upper step and bottom step of the platform.

CODE REFERENCE: OSHA 29 CFR 1910.25(b)(3).

RECOMMENDATION: Provide a proper transition from the circumferential stairway to the intermediate platform in accordance with OSHA. (Quantity: 2 steps)

ee. Ponding on Perimeter of Fixed Roof OBSERVATION: The fixed roof has standing water at the edge of the roof perimeter. Standing water will reduce the service life of the coating system.

CODE REFERENCE: UFGS 09 97 13.27

RECOMMENDATION: Remove the standing water from the fixed roof after periods of rain to extend the life of the coating system. Mechanically clean and recoat any defective coating promptly upon discovery during routine inspections in accordance with UFGS 09 97 13.27. (Quantity: 10 Areas)

ff. Center Roof Vent Configuration OBSERVATION: The fixed roof has a 12‐inch center roof vent in lieu of 24‐inch vent per AW 78‐24‐27 Drawing D.09 Detail 2.

CODE REFERENCE: AW 78‐24‐27 Drawing D.09 Detail 2 RECOMMENDATION: Replace the center roof vent per AW 78‐24‐27 Drawing D.09 Detail 2. (Quantity:

1)

gg. Fixed Roof Scaffold Cable Supports OBSERVATION: The fixed roof is not equipped with two 6‐inch Ø reinforced scaffold cable supports within 6‐feet of the center roof vent per AW 78‐24‐27 Drawing 5.02 Item V and API Standard 650 Figure 5.22.

CODE REFERENCE: AW 78‐24‐27 Drawing 5.02 Item V and API Standard 650 Figure 5.22.

RECOMMENDATION: Provide 2 scaffold cable supports on the fixed roof as shown in AW 78‐24‐27 Drawing 5.02 Item V. (Quantity: 2)

hh. Fixed Roof Circulation Vent/Inspection Hatch Configuration OBSERVATION: The fixed roof circulation vents/inspection hatches are carbon steel welded to the roof in lieu of being hinged stainless steel per AW 78‐24‐27 Drawing D.09 Detail 1. The intermediate rail of the roof perimeter handrail at these vents has carbon steel pipe in lieu of galvanized chain per AW 78‐24‐27 Drawing D.09 Detail 1 and Drawing D.11 Detail 5. The vents have a 6‐inch by 10‐inch inspection hatch on the vent. The inspection hatches are secured shut by a thin carbon steel chain.

The chains are heavily corroded and are too short to allow easy opening. Two of the ports cannot be opened due to the chains being too short.

CODE REFERENCE: AW 78‐24‐27 Drawing D.09 Detail 1 and Drawing D.11 Detail 5.

RECOMMENDATION: Replace the fixed roof circulation vents/inspection hatches in accordance with AW 78‐24‐27 Drawing D.09 Details 1 and 3. Replace the existing intermediate rails with 3/16‐inch galvanized chains with one end welded to the post and one end hocked to the other post in accordance with AW 78‐24‐27 Drawing D.11 Detail 5. (Quantity: 4)

ii. Obsolete Sample Gauge Hatch on Internal Ladder Access Hatch OBSERVATION: The access hatch for the internal ladder on the fixed roof has an obsolete 8‐inch sample hatch that was replaced by a dedicated sample gauge.

CODE REFERENCE: None.

RECOMMENDATION: Remove the obsolete 8‐inch sample hatch on the access cover for the internal ladder and install a lap‐welded plate. (Quantity: 1)

jj. Internal Coating Failure Under IFR legs OBSERVATION: The bottom appears to have never been coated under the floating roof support legs when the stainless steel bearing plates were removed in 2011. These locations do not show any signs of corrosion.

CODE REFERENCE: UFC 3‐460‐03 Section 8‐3.9(a)(1); UFGS 09 97 13.17 RECOMMENDATION: Mechanically clean and recoat the support legs in accordance with UFGS 09 97

13.17. (Quantity: 7 Legs)

kk. Inadequate Weld Spacing on Internal Receipt Line OBSERVATION: A lap‐welded pipe support pad for the receipt line diffuser does not have the required weld spacing of 2 inches between the pad and bottom lap‐weld…