Tank Consultants, Inc.

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Tank Consultants, Inc.

• 4333 West 21st Street
• Tulsa, Oklahoma 74107-3444
• 918-583-3968 Telephone
• 918-583-3966 Fax
• www.tank-consultants.com

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SPCC Tank Integrity Testing

• Presented By Kevin Kupitz

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Who has to test their tanks?

• If you have a facility with an aggregate oil
  storage capacity of 1320 gallons you must inspect
  all containers 55 gallons and above.
• Applies to owners/operators that use oil. This
  would include storage capacity of operating
  equipment.

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What type of facilities does this include?

• SPCC States
• oil of any kind or in any form, including but
  not limited to fats, oils, or greases of
  animal, fish or marine mammal origin vegetable
  oils, including oils from seeds, nuts, fruits, or
  kernels and other oils and greases, including
  petroleum, fuel oil, sludge, synthetic oils,
  mineral oils, oil refuse, or oil mixed with waste
  other than dredged oil

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Facilities such as

• Marinas
• General processing
• Refineries
• Pipelines
• Terminals
• Chemical plants
• Many other facilities

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SPCC plan review

• The original SPCC regulation was effective
  beginning January 10, 1974

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Revisions

• The new revision requires owner/operators to test
  above ground containers for integrity on a
  periodic basis.
• Most facilities should have a plan already that
  only requires revising.

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Schedule for the new plan

• Must have your SPCC plan amended by August 17,
  2004.
• Must implement your plan by February 18, 2005.

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Why should I inspect my tanks?
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Why should I inspect my tanks?

• To protect our environment.
• EPA will audit facilities as necessary.
• ND just fined 17 companies for over 400,000.00.
• Oxychem penalty of 137,500.00

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Issues

• Incomplete plan.
• Failure to inspect tanks, valves, piping and
  appurtenances.
• Failure to conduct integrity testing
• Lack of secondary containment for tanks.
• Inadequate secondary containment.

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What does an O/O have to do to comply?

• SPCC does not refer to or mandate the use of any
  industry standard as related to tank inspection.
  Although it states
• Consider the use of all relevant measures,
  including the use of industry standards, as a way
  to implement those measures.
• The decision in every case as to the
  applicability of any standard will be one for the
  P.E.

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What industry standards do we need to consider?

• API-653
• Written by tank builders, owners/operators and
  repair companies
• For self regulation rather than government
  regulation
• STI SP001-03 was written by
• Tank builders
• At the request of the EPA

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API-653 applies to

• API-650 Welded Steel Tanks for Oil Storage
• API-12C, the predecessor to API-650
• Any unknown standard
• API-653 Certified Inspector

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STI SP001-03 applies to

• Tanks SHOP built to any nationally recognized
  standard
• UL-142, 2085 and 2244
• API-650 Appendix J
• API-12F
• SwRI 97-04, 93-01
• lt50,0000 gallon tanks.
• STI Trained Inspector.

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What tests do we have to do to comply?

• Perform periodic Integrity Tests.
• Evaluate field constructed containers for Brittle
  Fracture during repairs, alterations or change in
  service.
• Record keeping.

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What constitutes an Integrity Test?

• SPCC states
• You must combine visual inspection with another
  testing technique such as hydrostatic testing,
  RT, UT, AE or another system of non-destructive
  shell testing.
• Test each above ground container for integrity
  on a regular schedule, and whenever you make
  material repairs.

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What does this mean?

• The actual inspection can be in accordance with
  STI SP001-03 or API-653 or a combination of both.
• Either way, the P.E. must sign off on the
  inspection technique.

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The tank inspection will be determined by a few
main variables

• SPCC states
• The frequency of and type of testing must take
  into account container size and design (such as
  floating roof, skid mounted, elevated, or
  partially buried).

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Example tank inspection for Field Erected
Vertical Tank on Grade.
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Example tank inspection for Field Erected
Vertical Tank on Grade.

• Monthly visual check by operator.
• 5 year external by a certified inspector by VT
  and UT methods while the tank is full.
• 10 year internal inspection incorporating VT, UT
  and/or MFL. Check tank bottom.
• As an option, the tank could be lifted exposing
  all sides of the tank.

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Vertical tank on Grade with Leak Detection.

• Monthly visual check by the operator.
• 5 year external inspection by a certified
  inspector with tank full of product.
• Internal inspection only when leaks are found or
  the integrity is questioned by the certified
  inspector.

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Horizontal Tank with all Sides Exposed.
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Horizontal Tank with all Sides Exposed.

• Monthly visual check by operator.
• Perform a 5 year external inspection with the
  tank full of product.
• Perform thorough Ultrasonic (UT) evaluation on
  the lower 60 degrees of the tank.
• Perform UT scrubs on the heads of the tank.

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O/O with many tanks
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O/O with many tanks

• Perform an Inventory/walk through inspection.
• Prioritize tanks by condition and location.
• Plan what needs to be done for all tanks to be
  integrity tested.
• Schedule the integrity Test.

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Test Techniques

• Ultrasonic Thickness Testing (UTT)
• Magnetic Flux Leakage (MFL) Floorscan
• Ultrasonic (UT) Corrosion Scanning (A-scan)
• Magnetic Particle Testing (MT)
• Visual Examination (VT)

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Ultrasonic Thickness Test
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MFL Floorscan
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Ultrasonic Corrosion Scanning
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Visual Inspection
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Holes from Soil Side Corrosion
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Weeps
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Conclusion

• Integrity Testing is accomplished by collecting
  the important tank variables and then determining
  what industry inspection standards make sense and
  then apply them.
• Your P.E. must approve them into the plan.

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Just remember, there are more painful things in
life!