Integrity Testing of Integrity Testing of Aboveground Storage Aboveground Storage

TanksTanks

2012 Southern Section AWMA Annual Meeting and Conference

Andrew Covington, P.E.

Presentation OutlinePresentation 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

IntroductionIntroductionAndrew 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

About Eco-Systems, Inc.About Eco-Systems, Inc.Full Service Environmental Consulting

FirmService Areas:

◦Permitting & Compliance,◦Natural Resources, ◦Remediation, ◦Planning, and◦Engineering & Construction

What Is An SPCC?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.

What Is Integrity Testing?What Is Integrity Testing?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.).

Why Should I Have My Why Should I Have My Storage Tanks Inspected?Storage Tanks Inspected?Workplace Safety ConsiderationsProtection of the EnvironmentIndustry Standards Good Engineering Practices Regulatory Requirements

Purpose of SPCC and tank integrity testing?

SPCC Regulations SPCC Regulations 40 CFR Part 112.8 (C) 640 CFR Part 112.8 (C) 6

Test or inspect each aboveground container for integrity on a regular schedule and 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 RegulationsSPCC Regulations40 CFR Part 112.8 (C) 640 CFR Part 112.8 (C) 6

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 Regulations SPCC Regulations 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 SPCC Regulations 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

Industry StandardsIndustry StandardsSteel Tank Institutes (STI) SP001American Petroleum Institute (API) 653National Fire Protection Association Fire

Code (NFPA 30)Local Fire Code(s)API 575 Atmospheric and Low Pressure

TanksAPI 570 Piping Inspection Code

STI SP001STI SP001Standard 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 SP001STI SP001At 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 SP001STI SP001Tank 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 SP001STI SP001

STI SP001STI SP001

STI SP001STI SP001Inspection Of Field-Erected ASTS

(Appendix B)

STI SP001 STI SP001 Periodic AST InspectionsPeriodic AST Inspections

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 Formal External STI SP001 Formal External and Internal Inspectionsand Internal Inspections

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 SP001STI SP001Suitability 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 SP001STI SP001Other 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 SP001STI SP001Recordkeeping (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.

Baseline ConditionsBaseline ConditionsASTs 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 ConditionsBaseline ConditionsASTs 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.

Hybrid Inspection ProgramHybrid Inspection ProgramThe P.E. may use industry standards,

along with other good engineering principles, to develop a customized inspection and testing program for the facility.

Environmental EquivalenceEnvironmental Equivalence◦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 EquivalenceEnvironmental EquivalencePetroleum 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 EquivalenceEnvironmental EquivalencePMAA 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 EquivalenceEnvironmental EquivalencePMAA 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.

Other ConsiderationsOther ConsiderationsNFPA 30Local Ordinances

Regulatory DeadlineRegulatory DeadlineCertain facilities were required to

comply by November 10, 2011.

Eco-Systems, Inc. ServicesEco-Systems, Inc. ServicesSPCC Plan Review and Update Integrity Testing Program Set Up STI SP001 Certified Tank InspectionsConsulting

Tank You!!!

Questions???Questions???