Integrity Testing of Aboveground Storage Tanks

1. Integrity Testing of Aboveground Storage Tanks 2012 Southern Section AWMA Annual Meeting and Conference Andrew Covington, P.E.

2. Presentation Outline Introduction About Eco-Systems, Inc. What Is Integrity Testing? Why Should I Have My Storage Tanks Inspected? SPCC Regulations Baseline Conditions Regulations/Industry Standards STI SP001 Hybrid Inspection Program Environmental Equivalence Other Considerations Regulatory Deadline Eco-Systems, Inc. Services Questions

3. Andrew Covington, P.E. • Professional Engineer • MS, AL, GA, LA, TX • Environmental/Petroleum Engineer • STI Certified Inspector • 30 Years of relevant Experience • Expertise • Permitting & Compliance • Air Quality • SPCCs & SWPPPs Introduction

4. Full Service Environmental Consulting Firm • Service Areas: • Permitting & Compliance, • Natural Resources, • Remediation, • Planning, and • Engineering & Construction About Eco-Systems, Inc.

5. What Is An SPCC? Federal regulation that requires a spill prevention control and countermeasure (SPCC) plan be in place. Designed to detect and prevent oil leaks, spills, or other potential integrity or structural issues before they can result in a discharge of oil to navigable waters of the U.S.

7. A test performed to determine the useful life of a Storage Tank. • Visual Inspection is an accepted integrity testing technique. • Non-destructive type shell testing (Hydrostatic Testing, Radiographic Testing, Ultrasonic Testing, Acoustic Emissions Testing, etc.). What Is Integrity Testing?

8. Workplace Safety Considerations • Protection of the Environment • Industry Standards • Good Engineering Practices • Regulatory Requirements Why Should I Have My Storage Tanks Inspected?

9. Purpose of SPCC and tank integrity testing?

16. Test or inspect each aboveground container for integrity on a regular scheduleand whenever you make material repairs. • You must determine, in accordance with industry standards, what are the appropriate qualifications for personnel performing tests and inspections, the frequency, and type of testing and inspections. • Take into account container size, configuration, and design. SPCC Regulations 40 CFR Part 112.8 (C) 6

17. You must inspect the container's supports and foundations. • You must inspect the outside of the container frequently for signs of deterioration, discharges, or accumulation of oil inside diked areas. • You must keep complete records. SPCC Regulations40 CFR Part 112.8 (C) 6

18. Testing on a ‘regular schedule’ means testing per industry standards or at a frequency sufficient to prevent discharges. Whatever schedule the P.E. selects must be documented in the Plan. SPCC Regulations

19. P.E. may choose to develop an inspection and testing program for the facility’s shop-built tanks in accordance with • STI SP001, • API 653, or • Hybrid Program SPCC Regulations

20. Steel Tank Institutes (STI) SP001 • American Petroleum Institute (API) 653 • National Fire Protection Association Fire Code (NFPA 30) • Local Fire Code(s) • API 575 Atmospheric and Low Pressure Tanks • API 570 Piping Inspection Code Industry Standards

21. Standard For The Inspection Of Aboveground Storage Tanks (Sept 2011, 5th Edition) • Section 1.2 states that SPOO1 standards are minimum requirements. • Applies to: • Aboveground Storage Tanks. • Storing Stable, Flammable, & Combustible Liquids at Atmospheric Pressure and having a Specific Gravity less than 1.0. • Operating Ambient Temperatures up to 200 Deg F. STI SP001

22. At a minimum, the following tank components shall be inspected (as applicable): • Primary tank • Secondary tank • Tank supports • Tank anchors • Tank foundation and external supports • Tank gauges and alarms • Insulation covering • Tank appurtenances • Normal vents • Emergency vents • Release prevention barriers • Spill control systems STI SP001

23. Tank Categories: • Category 1 • Secondary Containment • Continuous Release Detection Method (CRDM) • (Example - Elevated Tank where all sides of the tanks can be inspected except at the supports) • Category 2 • Secondary Containment • No CRDM – (Example - Tank shell in contact with soil) • Category 3 • No Secondary Containment • No CRDM STI SP001

24. STI SP001

25. STI SP001

26. Inspection Of Field-Erected ASTS (Appendix B) STI SP001

27. Conducted by Owner’s Inspector • The personnel performing these inspections shall be knowledgeable of storage facility operations, the type of AST and its associated components, and characteristics of the liquid stored. (4.1). STI SP001 Periodic AST Inspections

28. Conducted by Certified Tank Inspector (4.2) • A Certified Tank Inspector shall be certified by one or more of the following: • API Standard 653 Authorized Inspector Certification with STI SP001 Adjunct Certification. • STI Certified SP001 AST Tank System Inspector. • Additional certifications as may be required by individual states or other governing bodies. STI SP001 Formal External and Internal Inspections

29. Suitability for Continued Service (10.0) • Next formal internal inspection or the next formal external inspection, as applicable, may exceed the interval listed in STI SP001 (Table 5.5), if the corrosion rates allow and as determined by P.E. STI SP001

30. Other Tank Damage (10.3)- An AST requires evaluation by an experienced engineer or tank manufacturer to determine if further action is needed if tank subjected to damage caused by the following conditions : • Fire • Natural disaster • Excessive Settlement • Overpressure • Damage from Cracking STI SP001

31. Recordkeeping (11) • Retain each AST Record for the life of the AST. • Retain each Monthly Inspection Checklist for at least 36 months. • Retain each Annual Inspection Checklist for at least 36 months. • Retain each Portable Container Monthly Inspection Checklist for at least 36 months. • Retain all Certified Inspection Reports for the life of the AST. STI SP001

32. ASTs With Known Baseline Conditions • Shell thickness and • Corrosion rates Only when the baseline is known, an inspection and testing program can be established on a regular schedule as per Industry Standards. Baseline Conditions

33. ASTs With Unknown Baseline Conditions • For ASTs baseline conditions are not known, • A regular integrity testing program cannot be established. • P.E. must describe an interim schedule in the SPCC Plan. Baseline Conditions

34. The P.E. may use industry standards, along with other good engineering principles, to develop a customized inspection and testing program for the facility. Hybrid Inspection Program

35. 40 CFR 112.7(a)(2) – Allows deviations from some requirements when the owner provides equivalent environmental protection by some other means of spill prevention, control, or countermeasure. Environmental Equivalence

36. Petroleum Marketers Association of America (PMAA) SETTLEMENT LANGUAGE: • Well-designed shop-built containers with a shell capacity of 30,000-gallons or less • Visual inspection plus elevation of a shop-built container and makes all sides of the container, including the bottom, visible during inspection. Environmental Equivalence

37. PMAA SETTLEMENT LANGUAGE: • Visual inspection with placement of a barrier between the container and the ground, designed and operated in a way that ensures that any leaks are immediately detected. • P.E. should begin by consulting appropriate industry standards, such as those listed in Steel Tank Institute Standard SP001 and API Standard 653. Environmental Equivalence

38. PMAA SETTLEMENT LANGUAGE: • P.E. may wish to consult industry standards such as Underwriters Laboratory 142 or API Standard 650, Appendix J. • Where a facility is considering environmental equivalence approach for containers resting on the ground, or presents risks for corrosion, the facility should first evaluate the condition of the container in accordance with good engineering practices, including seeking expert advice, where appropriate. Environmental Equivalence

39. NFPA 30 • Local Ordinances Other Considerations

40. Certain facilities were required to comply by November 10, 2011. Regulatory Deadline

41. SPCC Plan Review and Update • Integrity Testing Program Set Up • STI SP001 Certified Tank Inspections • Consulting Eco-Systems, Inc. Services

42. Tank You!!!

43. Thank You….. Questions???