CommentsOn - My Committeesmycommittees.api.org/standards/cre/scast/Meeting Materials/Spri… · Web view(Affirmative) 6.2 Technical That we must “design to the design liquid level”

API Ballot Comments and Resolution

Ballot: 625 Compilation 2h Proposal: To ballot API 625 Compilation 2h. Ballot ID: 1350

Date: May 18, 2023

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Voter Name(Vote)

Clause No./Subclause No./Annex(e.g. 3.1)

Type of Comment

Comment (justification for change) by the Voting Member Proposed change by the Voting Member

Comment Resolution

John Mooney

(Negative)

Section 5 Technical 1) Number paragraphs, 5.1.1 etc. Comments on 5.1 follow:(2)Delete "barrier" and in most cases replace with "containment" (3) Both concepts...primary LIQUID barrier..(3) Leakage on failure of the primary LIQUID barrier..(4) the primary tank..steel TANK. Comments on 5.2 (5) Delete 1st par., not appropriate (6)4th par. inner tank provides primary LIQUID AND VAPOR containment.. See 3.2.3 (7) Delete 2nd and 3rd sentences. Comments on 5.3(8)Delete 1st & 2nd pars., we should not present history (9)Delete, US codes do not require blast and impact which are low probability events (10) par. 6 delete (11) Par. 7 delete -vapor barrier may not be neccessary, this belongs in DESIGN, not tank selection (12) Delete or shorten and move to an Appendix

per above

Randy Kissell

TGB Partnership

(Affirmative)

3.2.32 Editorial Change:

"Maximum liquid level that will be maintained during normal operation of the tank. Normally the level at which the high level alarm is set."

to:

"Maximum liquid level that will be maintained during normal operation of the tank, normally the level at which the high level alarm is set."

Randy Kissell

TGB Partnership

(Affirmative)


"Minimum liquid level that will be maintained during normal operation of the tank. Normally the level at which the low level alarm is set."

to:

"Minimum liquid level that will be maintained during normal operation of the tank, normally the level at which the low level alarm is set."

Randy Kissell 3.2.36 Editorial Change:

page 1 of 49API electronic balloting template/version April 2003



Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

TGB Partnership

(Affirmative)

"An event having the potential to cause harm, including ill health and injury, damage to property, product or the environment, production losses or increased liabilities"

to:

"An event that can harm health, property, or the environment"

Randy Kissell

TGB Partnership

(Affirmative)

5.1 Editorial Change:

"work should be detailed to go “over” bunds as opposed to through them."

to:

"work shall be detailed to go over bunds rather than through them."

Randy Kissell

TGB Partnership

(Affirmative)


"This is especially true for cryogenic gases where gaseous liquids can be up to 600 times their liquid form."

to

"This is especially true for cryogenic liquids where the volume of their gases can be up to 600 times the volume of the liquid."

Sheng-Chi Wu

Bechtel Corp

(Affirmative)

Section 1- Scope

Technical 1) Section 1.1:

add a paragraph to state "This Standard is applicable for refrigerated liquefied gas storage on land".

Please note that in the Title of the Standard (page 1), the term "ON LAND" can be deleted.

2) Section 1.2, fourth line:

add minus sign to 198 C, i.e. -198 C.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Sheng-Chi Wu

Bechtel Corp

(Affirmative)

Section 3 - Definitions


Suggest that each term should be defined following the alphabetical order.

2) Section 3.2.11:

After the title "operating liquid capacity", add "(Net Capacity)" so that it will be consistent with the term "net capacity" defined in Fig 6-1.

3) Provide definition for "moisture vapor barrier". This term is used often in all Figures, Section 5.

Sheng-Chi Wu

Bechtel Corp

(Affirmative)

Section 6 - Design Considerations


Change "normal maximum operating level" to "maximum normal operating level".

Change "normal maximum and minimum operating levels" to "maximum and minimum normal operating levels", so that they are consistent with the definition presented in Section 3.

2) Fig 6-1:

2a) Change to "maximum normal operating level", and "minimum normal operating level.

2b) Change "operating freeboard" to "seimsic freeboard see 6.5.9, since the freeboard above the design liquid level should be also calculated per Section 6.5.9.

3) Section 6.3.9, third line:

Change "or separate the cooling effect of the tank ----" to "or provide elevated foundation to separate the cooling effect ----".




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

4) Section 6.6.6, 4th line:

Change "foundation capacity" to "pile capacity".

Anant Thirunarayanan

Bechtel Corporation

(Affirmative)

1.3 Technical In Section 5.0, "primary" and "secondary" have been used in a different sense. For example, the "primary" vapor barrier is the outer container whereas the word "primary containment" is used for inner container. Will the word "primary" get confused?


Bechtel Corporation

(Affirmative)

5.1 Technical "Both concepts are designed and constructed so that only the primary vapor barrier contains the liquid and therefore …." - This is not true. This should be reworded.


Bechtel Corporation

(Affirmative)

5.3 (4th para)

Technical The contents of this paragraph are repetition of contents of 3rd paragraph.


Bechtel Corporation

(Affirmative)

5.3 (9th para)

Technical Reference to historical aspects should be avoided. Propose the wordings as shown.

Essential to the concept of a full containment is the assured leak-tightness of the primary liquid container. Liquid is not permitted to accumulate outside the primary liquid container during normal operation. Tank systems




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

where this is not assured amount to a somewhat different storage concept and would require consideration of such things as liquid collection and disposal, potential cold spots, affect on tank venting, etc. This standard has not attempted to address these issues. Such systems include tank systems with concrete primary liquid container with or without liners.


Bechtel Corporation

(Affirmative)

6.3.2 (3ra para)

Technical ACI 376 is referred here. However, detailed description of concrete storage system is not given in Section 5.0. Either this should be deleted or this type should be described in Section 5.0.


Bechtel Corporation

(Affirmative)

6.3.3 Technical "…….safe for personnel access." - When the tank system is decommissioned, it shall be not only safe for personnel access but also safe for hot work.


Bechtel Corporation

(Affirmative)

6.4.3 Technical Since we have not detailed or defined "Liquefied gas metal container" earlier, can we use the same terminology that was used in Sections 1.0 and 5.0.


Bechtel Corporation

9.3.2.1 Technical PVC is not a closed cell and should not be used as this will permeate gas.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)


Bechtel Corporation

(Affirmative)

9.4.2.1 Technical This section is specifically for single wall single containment tank system with external insulation. It would read better if the type of tank is also specified.


Bechtel Corporation

(Affirmative)

9.5.4 Technical Adhesive shall not be used. Mechanical attachment shall be specified.


Bechtel Corporation

(Affirmative)

9.6 Technical "deck seam must be sealed" "deck seams must be seal welded".


Bechtel Corporation

(Affirmative)

9.8.4 Technical To be deleted.

Ben Ho

BP America

(NonVoter)

1.2 Technical In section 1.2, the temperature of 198C should be -198C.

In section 1.2, the temperature of 198C should be -198C.

Jack Blanchard

Chicago Bridge & Iron (CBI)

1.2 Editorial “stored liquids which boil at ambient temperature” I think can be better described as in gaseous state at ambient temperature.

Change wording as follows:

“stored liquids which are in their gaseous state at ambient temperature and pressure”




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Jack Blanchard


(Affirmative)

1.3 Editorial Suggest changes to the wording to clarify containments.

Secondary containment is required for single containment tanks in the form of a dike or bund.

Change second sentence wording to as follows:

“All configurations consist of a primary liquid and gas containment constructed of metal, concrete, or a metal/concrete combination and a secondary liquid containment.

Jack Blanchard


(Affirmative)

1.6.c Editorial The wording in parenthesis contradicts the requirement itself. Delete it.

Delete the entire parenthetical statement.

Jack Blanchard


(Affirmative)

1.6 Technical Need to address piping beyond the first flange or weld for components that serve only the tank such as relief valve piping and valves.

1.6.d The complete external, pressure containing, piping connection which serves only the tank, (such as pressure relief valve, and instrumentation connections).

Jack Blanchard


(Affirmative)

3.2.2; 3.2.3; & 3.2.4

Editorial To reduce potential conflicts and/or flipping from section to section, suggest that these definitions be moved to section 5 and placed at the start of paragraphs 5.1; 5.2; & 5.3.

Move current wording to section 5 and add the following:

"See section 5.1" (etc)

Also, change the first words of 3.2.3 and 3.2.4 to:

“A double containment system is comprised of a . . .” and

“A full containment system is comprised of a . . .”

Also, change the second




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

sentence of 3.2.4 to

“Both liquid containers are . . . “

Jack Blanchard


(Affirmative)

3.2.7 Editorial The term “warm vapor container” can be confused within the standard with purge gas container, and vapor barrier

Change the term to:

Warm Product Vapor Container

Like changes will be needed elsewhere in the standard.

Jack Blanchard


(Affirmative)

3.2.10 Editorial End of sentence is confusing Change “position for a” to

“Condition at or near”.

Jack Blanchard


(Affirmative)

3.2.12 Editorial Freeboard is to prevent overflow OR damage to the roof.

Change the word “and” to “or”

“ . . . to minimize or prevent overflow or damage to the roof . . .”

Jack Blanchard


(Affirmative)

3.2.13 Technical The term can be defined more simply. Change definition as follows:

Wave motion of the stored liquid due to seismic ground movement.

Jack Blanchard


(Affirmative)

3.2.14 Editorial The standard uses primary and secondary container in place of inner and outer shell or wall.

Change the definition as follows:

The space between the primary liquid container and the primary product vapor container or purge gas container of a double wall




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

tank.

Jack Blanchard


(Affirmative)

3.2.21 Editorial Editorial change to account for use behind the TCP Delete “base”

Jack Blanchard


(Affirmative)

3.2.22 Editorial Suggest a change to prevent freezing of water rather than frost and to account for ring wall supported tanks.

Change wording as follows:

“ A heating system provided in the base slab or soil below the tank to prevent freezing of the soil and frost heave.”

Jack Blanchard


(Affirmative)

3.2.24; 3.2.25; 3.2.26

Editorial 3.2.24; 3.2.25; & 3.2.26

To eliminate potential conflicts and the need to flip between sections just reference section 6

Change as follows:

Delete definition and add:

See section 6.4.2

Jack Blanchard


(Affirmative)

3.2.29 Editorial 3.2.29

Vacuum is not achieved. Only a pressure below ambient pressure

Change as follows:

“The internal tank pressure, below ambient pressure, at which . . . “

Jack Blanchard


(Affirmative)

3.2.31 Editorial 3.2.31

The DLL doesn’t necessarily need to be maintained

Change “maintained” to “experienced” or “reached”

Jack Blanchard

Chicago Bridge &

3.2.32 & 3.2.33

Editorial 3.2.32 & 3.2.33 Consider deleting the second sentence from these definitions




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Iron (CBI)

(Affirmative)

Do we want to state instrument criteria here? and leaving the level alarm requirements for section 7.4

Jack Blanchard


(Affirmative)

3.2.37 Technical 3.2.37

New definition for term used in 6.2 similar to that used in API 2350

Add “Overflow Protection Margin”

Add new paragraph:

Overflow Protection Margin

Capacity (tank height or volume) between the maximum normal operating level and the maximum design liquid level.

Jack Blanchard


(Affirmative)

3.2.28 Technical 3.2.28

New definition for term Maximum Liquid Capacity

This term is used in NFPA 59A and is consistent with other liquid level terms in API 625

Add new paragraph

Maximum Liquid Capacity

Total volumetric liquid capacity between the tank bottom and the maximum design liquid level. (Also referred to as total liquid capacity in API 620)

Jack Blanchard


(Affirmative)

Editorial 4.1

Add “system” to the end of the second sentence

Jack Blanchard


(Affirmative)

4.2.1.1 Editorial 4.2.1.1

change “listed” to “determined”

Jack Blanchard


4.2.1.13 Editorial 4.2.1.13

Add “Maximum” before “design”




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Jack Blanchard


(Affirmative)

4.2.1.24 Technical 4.2.1 Need to provide for items identified in assessment of risks

Add:

4.2.1.24

Limiting criteria and conditions resulting from assessment of risks such as pressure wave, impact load, fire, etc

Jack Blanchard


(Affirmative)

4.2.1.16 Editorial 4.2.1.16

“blast” has negative connotations and the tank designer needs to design for a pressure wave, not a blast.

Move requirement to 4.2.1.24 and change blast to pressure wave.

Jack Blanchard


(Affirmative)

4.2.1.25 Technical 4.2.1.25 – new item

Overflow protection capacity

Add item

Basis for determining overflow protection capacity (refer to API 2350 for guidance)

Jack Blanchard


(Affirmative)

4.2.1.26 Technical 4.2.1.26

new item

Min normal operating level basis

This could be the minimum level for pump restart, or minimum pump down level.

Add item

Basis for determination of minimum normal operating level

Jack Blanchard


5.0 Technical 5.0

A general introduction paragraph would be helpful clearly limiting concepts covered by this standard.

Suggested wording:

This standard is limited to the storage concepts defined in this section. Variations of the




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

This paragraph would account for membrane tanks, spheres, and a primary concrete tank design that allows liquid to migrate through the walls of the tank.

The paragraph needs to make clear that these concepts may be viable, but they are not covered in this standard, at least not at this time.

examples provided are acceptable provided they meet the minimum requirements defined in this section. Other storage concepts falling outside those defined in this standard may be possible but require a thorough evaluation by the owner and authority having jurisdiction of design and operation issues not incorporated in this standard.

Jack Blanchard


(Affirmative)

5.1; 5.2; 5.3 Technical 5.1; 5.2; & 5.3

Need concise definition to start each section with.

Move 3.2.2; 3.2.3; & 3.2.4 to be the first paragraph of each of these sections.

Jack Blanchard


(Affirmative)

5.1; 5.2; 5.3 Technical 5.1; 5.2; & 5.3

These sections need to just state requirements of the standard. There is a considerable portion of information that is useful but is more for information that a requirement. Suggest that a good portion of these sections be moved to an appendix, similar to other guidance

Jack Blanchard


(Affirmative)

5.1 Technical 5.1

The bulleted items can be cleaned up to fit with the initial definition from section 3

Suggested new wording for first part of 5.1:

5.1 Single Containment

Add definition from 3.2.2

The single containment concept shall comprise one of the




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

following:

• A single wall tank system designed and constructed to provide primary liquid and vapor containment

• A tank system comprising both inner and outer containers. The inner container is designed and constructed as the primary liquid container. The outer container is designed and constructed as the warm product container and vapor barrier.

• A tank system comprising of both iner and outer containers. The inner container is designed and constructed as the primary liquid and vapor container. The outer container is designed and constructed as the purge gas container and vapor barrier.

Jack Blanchard


(Affirmative)

5.1 Technical 5.1

Last text paragraph

Process piping including configuration requirements such as penetrations below the liquid line are contained in section 7.2.1. We need to make sure there are no conflicts.

Suggest reducing the content and referencing paragraph 7.2.1.3 for requirements.

Jack Blanchard

Chicago Bridge &

5.2 Technical 5.2

Other than the definition moved from section 3, all of page 13 of 49

API electronic balloting template/version April 2003



Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Iron (CBI)

(Affirmative)

the words in this section can be moved to the appendix.

Jack Blanchard


(Affirmative)

5.3 Technical 5.3

The first 2 paragraphs including the bullets can be moved to the appendix.

The information in the third and forth paragraphs should be combined with the base definition from section 3 to define the concept.

Most of the remainder of the content can be moved to the appendix, or there is some redundancy or possible conflict with ACI that needs to be reviewed.

Paragraph 6 comments on roof collapse as a non-credible event. This may be placed in the appendix, but the comments must also consider NFPA 59A rules for determining exclusion distances (which assume the roof over the secondary containment has disappeared).

Jack Blanchard


(Affirmative)

5.4 Technical 5.4

Storage concept selection is a customer requirement. However, many customers need guidance. I suggest that we place most of this paragraph in an appendix.

Reference should be made to paragraph 6.1

Jack Blanchard


(Affirmative)

5.4 Technical 5.4.2

Hazard Identification

This assessment of risks is the responsibility of the owner but I do not think we should define how the




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

customer performs his assessment of risks. This guidance should be placed in an appendix.

Jack Blanchard


(Affirmative)

6.0 Technical Title

This section contains more than just considerations. We should change the title

Change title to

Design

Jack Blanchard


(Affirmative)

6.0 Technical 6.0

The section provides more than just guidance

Change guidance to requirements

Jack Blanchard


(Affirmative)

6.1 Technical 6.1

Spacing requirements

This is a customer requirement, we should say that

Add

“Determination by Owner/Purchaser of “ in front of Spacing . .

Jack Blanchard


(Affirmative)

6.2 Technical 6.2

Title should change

Change title to

Design Liquid Levels and Volumes

Jack Blanchard


(Affirmative)

6.2 Technical 6.2

With the addition of Figure 6-1 revise wording.

Change paragraph to the following:

Liquid levels and volumes used in this standard for design of the tank system are defined in section 3. Figure 6-1 provides a graphical representation of the relationship of the terms used.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Jack Blanchard


(Affirmative)

Ftg 6-1 Technical Figure 6-1

Several terms need to be revised to be consistent with the terms of the standard

Revise the figure as follows

Change Gross Capacity to Maximum Liquid Capacity and show the top dimension line at the maximum design liquid level.

Delete operating freeboard and replace with 1’-0 (300mm)

Add a term between the the Max NOL and the Max DLL “Overflow Protection Margin”

Change Net capacity to Net working capacity

Change Normal Maximum OperationLevel to Maximum Normal Operating Level

Change NMinOL to MinNOL

Jack Blanchard


(Affirmative)

6.3.2 Editorial 6.3.2

move 4th paragraph to be part of first paragraph

Jack Blanchard


(Affirmative)


3rd bullet

Need to use terms of the standard and allow for a primary containment concrete tank

Change wording as follows

Concrete primary of secondary liquid container wall.

Jack Blanchard 6.3.8 Editorial 6.3.8 5th bullet Change wording as follows




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution


(Affirmative)

Add to end

“including connecting piping”

Jack Blanchard


(Affirmative)

6.3.10 Technical 6.3.10.a and .b

Need to move the reference to OLE and CLE to where the definition terms OBE and SSE are referenced

Move last sentence as follows

from 6.3.10 a and b to

6.4.2

Jack Blanchard


(Affirmative)

6.4.1 Technical 6.4,1

item 2 of additional loads

Change as follows

Change loads based on a risk assessment to

Loads specified from an assessment of risks . . .

Change term blast to pressure wave

Jack Blanchard


(Affirmative)

6.5.5 Technical 6.5.5

clarification of should and shall

Change as follows

End of first sentence: Change to “(SSI) shall be considered.”

Middle of second sentence:

Change to “parameters should be included”

Jack Blanchard


(Affirmative)

6.7 Technical 6.7

Need to allow for low temperature concrete wall tanks (such as LPG) that do not need a metallic type TCP

First paragraph:

Reverse the subject of the two sentences.

Second paragraph:




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Change beginning of first sentence to:

“A standard solution for tank systems storing product below -60oF applies . . . “

Jack Blanchard


(Affirmative)

7.2.1.3.c Technical 7.2.1.3.c

Adding on to what Doug Miller has suggested, I think there are further changes needed.

NFPA 59A does not specifically exclude shell penetrations in double and full containment tanks.

The remote bund volume needs to be defined. I suggest that it be sized for a limited volume necessary to close off the ITV.

Change DGM wording as follows:

ii delete "(e.g. NFPA 59A)"

iii Add to end "The volume contained by the bund shall equal 110% of the flow from a full line break prior to closure of the ITV in iv below."

Jack Blanchard


(Affirmative)


The reference to paragraph 7.2.1.3 is confusing

Top and bottom fill lines function is independent of how they enter the tank

Delete the term in parenthesis.

Jack Blanchard


(Affirmative)


The second sentence is not clear

Change the second sentence to read:

“A separate, liquid level alarm & cutoff device is also required.”

Jack Blanchard

Chicago Bridge &


The specific solutions to the requirement are not

Delete last sentence and bulleted items.




Date: May 18, 2023

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Voter Name(Vote)


Type of Comment


Comment Resolution

Iron (CBI)

(Affirmative)

needed and may be unnecessarily restrictive

Jack Blanchard


(Affirmative)


The wording can be made more clear

Change wording to the following:

Temperature monitoring devices for the primary liquid container shall be provided to monitor liquid and vapor temperatures during cool down of the primary liquid container.

Jack Blanchard


(Affirmative)

7.5.3 Technical 7.5.3

Most facilities will install an accelerometer rather than a seismometer.

Add to the second sentence as follows:

A seismometer or accelerometer, located in the plant away from major foundations may be required to determine OBE exceedance.

Jack Blanchard


(Affirmative)

8.2 Editorial 8.2

second paragraph

Suggest clarification in the wording

Change wording of first sentence of 2nd paragraph as follows:

“The QA/QC requirements for construction contained in the applicable design and construction standards such as . . . “

Jack Blanchard


(Affirmative)

10.3.3 Technical 10.3.3

Current API 620 version change only requires liquid lines to be pressure tested. Delete reference to vapor lines.

Change first sentence as follows:

“Piping subject to liquid flow, . . . “




Date: May 18, 2023

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Voter Name(Vote)


Type of Comment


Comment Resolution

Larry Hiner

Chicago Bridge & Iron Company(CB&I)

(Affirmative)

3.2.1 Editorial 3.2 1 – Reorder in alphabetical order after all definitions are set.

Larry Hiner


(Affirmative)

3.2.1 Technical 3.2.1 for consistency, use the term “vapor container” instead of “containment for vapor” and move before insulation.

The combination of a primary liquid container, together with secondary liquid container (if any), vapor container, insulation, appurtenances,- - -

Larry Hiner


(Affirmative)

3.2.3 Editorial 3.2.3 In distinguishing between the double containment and full containment the control of vapors is an important concept. Add “or control

The secondary container is designed to hold all the liquid contents of the primary container in the event of leaks from the primary container, but is not intended to contain or control any vapor resulting from product leakage from the primary container.

Larry Hiner


(Affirmative)

3.2.9 Technical Bund wall is used within the body of the standard however US standards typically use dike wall. I'd rather see dike wall thoroughtout either can be used as long as there is consistancy.

A dike wall is to contain spilled liquids and may not be limited to those that are flammable.

3.2.9 Dike Wall

A structure used to establish an impounding area which is used for the purpose of containing any accidental spill of stored liquid. Sometimes this structure is referred to as bund wall.

Larry Hiner

Chicago Bridge & Iron

3.2.10 Technical The words “in its operating position” do not apply. This is a gas pressure and should be so stated. The design standards allow for higher pressures during venting. I

Design Pressure

The gas pressure (gauge) above the liquid level for which the




Date: May 18, 2023

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Voter Name(Vote)


Type of Comment


Comment Resolution

Company(CB&I)

(Affirmative)

suggest the following : system is designed. This pressure is at least the pressure at which the relief valve(s) open. Overpressure during venting shall be limited as required by API 620 or ACI 376 as applicable.

Larry Hiner


(Affirmative)

3.2.11 Technical Add new term “Maximum Liquid Capacity” and renumber. Note “Nominal Liquid Capacity” is used by NFPA and API 620 which require the nominal liquid capacity to be shown on the nameplates. Maximum Liquid Capacity is a preferred term.

Maximum Liquid Capacity (sometimes referred to Nominal Liquid Capacity)

The total volumetric liquid capacity of the tank between the design liquid level and the tank bottom.

Larry Hiner


(Affirmative)

3.2.11 Technical Operating Liquid Capacity should be changed to Maximum Normal Operating Capacity. Capacity (minimum net working) is used in 4.2.1

3.2.11 “Maximum Normal Operating Capacity”

Capacity from Maximum Normal Operating Level to the tank bottom.

Larry Hiner


(Affirmative)

3.2.11 Technical Add Net Working Capacity

The net working capacity of the tank for refrigerated product is the volume contained between the Maximum Normal Operating Level and the Minimum Normal Operating Level.

“Net Working Capacity”

The usable volume contained between the Maximum Normal Operating Level and the Minimum Normal Operating Level.

Larry Hiner

Chicago Bridge &

3.2.12 Technical I don’t think “damage to the roof” is the main concern. I’d rather see “damage to the tank system”




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Iron Company(CB&I)

(Affirmative)

Freeboard is not a concern for ALE. I think you should just eliminate the terms (OLE, CLE and ALE) from this definition.

Larry Hiner


(Affirmative)

3.2.13 Technical Define “sloshing wave height” instead of just “sloshing” Sloshing Wave Height

Wave height above the static liquid level resulting from fluid motion during a seismic event.

Larry Hiner


(Affirmative)

3.2.14 Technical Since terminology for concrete may be different I suggest using inner container and outer container instead of shell.

I suggest “The space between the inner container and outer container.”

Larry Hiner


(Affirmative)

3.2.20 Editorial TCP is used only for the liquid containers. Add the word “liquid”

Thermally insulating and having a liquid tight structure in the bottom annular section of a tank system to protect the secondary liquid container against low temperatures in the event of leakage from the primary container

Larry Hiner


(Affirmative)

3.2.29 Editorial Set vacuum is actually not used in the text of the API 625 and is therefore not required and should be deleted

Larry Hiner


3.2.31 Editorial To be consistent with Fig 6-1 delete the word “Maximum” This is a design level not a level the product will necessarily be maintained.

3.2.31 Design Liquid Level

The maximum height that the product can be safely stored and




Date: May 18, 2023

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Voter Name(Vote)


Type of Comment


Comment Resolution

Company(CB&I)

(Affirmative)

is used in the static shell thickness determination.

Larry Hiner


(Affirmative)

3.2.35 Technical Design metal temperature has significant meaning for API 620 designs however ACI 376 rarely uses this terminology. This is thoroughly covered in 6.3.6

3.2.35 Minimum Design Temperature (or Design Metal Temperature)

See 6.3.6 for definition

Larry Hiner


(Affirmative)

4.2.1.3 Technical Use terminology “Net Working Capacity”

Larry Hiner


(Affirmative)

4.2.1.5 Technical Delete “Design Life” as information from the Purchaser. This is superfluous unless there is also a corresponding requirement. Specifying the number of loading full cycles also doesn’t trigger any requirement.

Larry Hiner


(Affirmative)

4.2.1.11 Technical Move Pressure /vacuum relief value set points to under 4.2.3

Larry Hiner


4.2.2.1 Editorial Use terminology “Maximum Liquid Capacity(or Nomonal Capacity)"




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Larry Hiner


(Affirmative)

4.2.3.5 Technical NDE is not limited to welds (eg., concrete joints ) NDE applied to non-hydrostatically tested components.

Larry Hiner


(Affirmative)

5.0 Technical Most of this section should be moved to an appendix. The requirements descriptions of the configurations should be in Section 5. The history and benefits should be in an appendix.

Also, number all paragraphs and figures.

Larry Hiner


(Affirmative)

5.1 Technical Dike walls should be used instead of bund wall since this is terminology used in USA codes and standards (e.g. NFPA and API uses Dikes)

Replace “bund” with “dike” in all locations of the standard.

Larry Hiner


(Affirmative)

5.1 Technical The word steel is through this section. Replace the word “steel” with “metal”.

Replace “steel” with “metal” in all locations of section 5.0.

Larry Hiner


(Affirmative)

5.1 Technical Since it is important to reduce surface area in the event of a spill, there should be a requirement to place dikes at a maximum distance from the tank. Suggest 40 feet.

Larry Hiner

Chicago Bridge &

5.1 Technical There are significant rules for secondary liquid containers why isn’t there any rules here for dike




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Iron Company(CB&I)

(Affirmative)

walls?

Larry Hiner


(Affirmative)

5.1 Technical Some variations of tank concepts are provided but certainly not all. Add the Word “Some”. Also, this is a single containment not a single tank.

Some variants of single containment concepts comprising a single containment are as follows:

Larry Hiner


(Affirmative)

5.2, Technical 1st paragraph – This discusses a “liquid spill”, 5.1 3rd paragraph uses “Leakage”, and 5.3 1st paragraph discusses tank failure. Should these all be the same or state why different terminology is used

Larry Hiner


(Affirmative)

5.2, Technical 5th paragraph – an earthen embankment is noted however not show in the sketches. Is this also a possible option for full containment?

Move this to commentary and explain

Larry Hiner


(Affirmative)

5.2, Technical 7th paragraph, last sentence – Change should to shall and 6 m to 20 ft

To minimize evaporation the secondary liquid container shall be located at a distance not exceeding 20 feet from the primary liquid container.

Larry Hiner


(Affirmative)

5.3, Technical 7th paragraph, last sentence. It is not necessary to state that metallic secondary containers are assumed to be vapor tight. If a statement is necessary just say - metallic containers are designed to be vapor tight.

Delete last sentence




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Larry Hiner


(Affirmative)

5.4.2.2, Technical 2nd bullet- Overfilling concerns are not limited to export facilities and are probably more of a concern for import facilities.

Delete the words “i.e., at export facilities with high run down rates to single/multiple tanks”

Larry Hiner


(Affirmative)

5.4.2.3 Technical Minor rewording would be helpful. Change “out with” to “outside of” and remove the word ”then”

Where the hazard assessment identifies risks that are outside of acceptable limits, positive measures (action) shall be taken to reduce the level of risk to an acceptable level.

Larry Hiner


(Affirmative)

6.2 Technical Figure 6-1 Change terminology to agree with section 3 and other API standards

Change gross capacity to a

Add a level to the design liquid level and the terminology title “Maximum Liquid Capacity”

Change Net Capacity to “New Working Capacity”

Change “Normal Maximum Operating Level” to “Maximum Normal Operating Level”.

Change “Normal Minimum Operating Level” to “Minimum Normal Operating Level”

Delete Operating Level

Add “Overfill Protection Distance” between Design Liquid Level and Maximum Normal Operating Level

Add “Maximum Normal Operating Capacity” defined as capacity from bottom to Maximum Normal Operating Level

Larry Hiner 6.3.2 Technical 4th paragraph- revise normal maximum liquid level to




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution


(Affirmative)

maximum normal operating level for alignment with definitions

Larry Hiner


(Affirmative)

6.5.8 Technical Add an overflow or automatic shut-off valves as possible means to restrict product level

6.5.8 Seismic Design Liquid Height

If the tank system includes an overflow or sufficient high level alarms or automatic shut off valves to restrict the maximum normal operating level to a level lower than the maximum design liquid level, the maximum normal operating level may be applied to all seismic design including freeboard determinations.

Larry Hiner


(Affirmative)

6.3.10 Technical 1st sentence- Only tanks with secondary liquid containers must be designed for the ALE seismic motion. All tanks must be design for two levels and those with secondary liquid containers three levels.

Containments designed and built to this standard shall be designed for two levels of seismic motion. A third level design is required for double and full containments.

Larry Hiner


(Affirmative)

6.3.10c Technical This applies to a secondary liquid container. The volume it must contain is the volume of the primary liquid container to the maximum normal operating level (maximum normal operating capacity)

Aftershock Level Earthquake (ALE): The tank system, while subjected to ALE, shall provide for no loss of containment from the secondary “liquid” container while containing the primary container maximum normal operating capacity.

Larry Hiner 6.4.3 Technical There is no need to state liquefied gas (three times) in The design loads shall be page 27 of 49




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution


(Affirmative)

this paragraph because the standard is only for liquefied gas containers.

I think the following is an improvement

combined to produce credible load combinations to be used in the design. See API 620 for guidance on the load combinations for metal containers and ACI-376 for concrete containers.

Larry Hiner


(Affirmative)

6.6.1, Technical 3rd paragraph - It is stated that foundation integrity must be maintained under normal operating conditions. Why is this not true for emergency or abnormal conditions? Clarification is required.

Larry Hiner


(Affirmative)

6.6.4, Technical 1st sentence replace “vis. With more normal terminology – “ i.e., “

In general, the design soil parameters (i.e., bearing capacity, pile compression and tension capacities etc.) are based on allowable - - -

Larry Hiner


(Affirmative)

9.4.2.3 Technical Only carbon steel tanks require painting of coating Add “carbon” before the word “steel”.

Larry Hiner


(Affirmative)

10.3.2 Technical change reference form 8.2.3 to 7.2.3

Douglas Miller


1.1 Editorial “associated systems” sounds like its talking about things like exchangers, compressors and the like out in the facility which we do not address.

Replace “tanks and their associated systems” with “tank systems”




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Company(CB&I)

(Affirmative)

Douglas Miller


(Affirmative)

1.2 Editorial Add minus sign in front of 198C.

Douglas Miller


(Affirmative)

1.5 Editorial 3rd line: replace “contains” with “containers” .

Douglas Miller


(Affirmative)

1.6 Editorial “the wall” is not a clear word in this context in this std. But since we mention bund walls and show bund walls in figures in section 5, we probably should be clear in 1.6 that they are actually outside scope of API 625.

I suggest we replace “the wall” with “ the liquid, vapor, and any purge gas containers (but excluding bund walls)”

Douglas Miller


(Affirmative)

1.6.c Technical Requiring connections to have flanges is not appropriate and even if it was it would belong in section 7, not section 1.

Delete the parenthetical statement about extension and flanges.

Douglas Miller


(Affirmative)

3.2.2, 3.2.3 and 3.2.4

Editorial 3.2.2, 3.2.3 and 3.2.4 should all just refer to sections 5.1, 5.2 and 5.3. The content of 3.2.2, 3.2.3 and 3.2.4 should be moved to section 5.

Douglas Miller 3.2.9 Editorial The term used in section 5 is “bund wall” Replace “Dike Wall” with “Bund page 29 of 49




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution


(Affirmative)

Wall”

Douglas Miller


(Affirmative)

3.2.9 Technical Clarify that the bund wall term does not refer to the secondary containment of a double containment system. Also, contained product is not necessarily flammable.

“A structure REMOTE FROM THE TANK SYSTEM used to establish an impounding area ….stored LIQUID”

Douglas Miller


(Affirmative)

3.2.13 Editorial OLE and CLE have their alternate names OBE and SSE which are used in section 6. Why get into this terminology if not necessary. I think its not necessary for the definition of sloshing.

I suggest deleting “(OLE, CLE and ALE)”

Douglas Miller


(Affirmative)

3 Technical “Primary vapor container” is used many times in API 625 and should be defined.

Douglas Miller


(Affirmative)

4.2.1.19 Editorial Section reference numbering correctons needed Should be 6.3.5 and 7.4.4

Douglas Miller


4.2.1.20 Editorial Section reference numbering correctons needed Should be 7.2 and 7.4




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Douglas Miller


(Affirmative)

4.2.1 Technical There are a few items in this list that don’t always apply. All of these should be grouped together at the end of the list and identified (as we already have for CP) as “if any” or as “if applicable” items. The point is to avoid implications such as that design for some level of blast is mandatory.

Items I see as “if any” or “if applicable” type are following:

4.2.1.16 Accidental loads (such as fire, blast/ impact)

4.2.1.17 cathodic protection system

4.2.1.19 Spillage handling requirements

4.2.1.20 Required rollover prevention provisions

4.2.1.23 Hazard protection system requirements (such as water spray, gas detection)

Douglas Miller


(Affirmative)

5 Other In general I think this section is too long and contains quite a bit of material that while useful is really tutorial or commentary in nature. Paragraphs that I believe are in this category are:

Last 3 paragraphs of 5.1

1st, 2nd, 3rd, 6tth and 7th paragraphs of 5.2

1st and 2nd paragraph of 5.3

Most of 5.4.

Move this material into an informative appendix. This will essentially require a rewrite. Many or most of existing words could be used, but a lot of reorganizing.

Douglas Miller


5 Editorial Add section numbering to each paragraph




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Douglas Miller


(Affirmative)

5.1 Editorial We should use the term defined in section 3, i.e. “primary LIQUID CONTAINER”, rather than “primary VAPOR BARRIER”.

Douglas Miller


(Affirmative)

5.1 Technical This section properly opens with a definition of Single Containment. But draft says that outer shell provides vapor containment. We should also address double wall – double roof tanks where the inner tank provides the vapor containment.

Use the definition currently given in 3.2.2 which handles this correctly. Actually best style is to move the 3.2.2 definition into 5.1 and just have the 5.1 reference in 3.2.2.

Douglas Miller


(Affirmative)

5.2 Editorial This section should open with a definition of Double Containment Tank System to parallel with the opening statements of 5.1.

The definition should be moved into 5.2 from 3.2.3 and just 5.2 reference left in 3.2.3

Douglas Miller


(Affirmative)

5.3 Editorial This section should open with a definition of Double Containment Tank System to parallel with the opening statements of 5.1.

The definition should be moved into 5.3 from 3.2.4 and just 5.3 reference left in 3.2.4

Douglas Miller


(Affirmative)

5.1, 5.2 and 5.3

Technical It should be clear that the sketches are not the only permitted arrangements.

Each line introducing the configuration sketches should say “SOME variants of ….” Or “EXAMPLES of ….”

Douglas Miller

Chicago Bridge &

5.1 Editorial Intro to second set of figures indicates independent vapor barrier but even the first set have independent

“SOME variants of single containment concepts using




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Iron Company(CB&I)

(Affirmative)

moisture vapor barriers. BOTH INNER AND OUTER TANKS.

Douglas Miller


(Affirmative)

5.2 Technical 3rd paragraph, last sentence: While it is not normally done, I think that it is possible to have piping through the liquid containers and still be a double containment concept.

“”” Piping penetrations are not permitted through the PRIMARY OR SECONDARY LIQUID CONTAINERS EXCEPT WHERE SPECIFICED BY PURCHASER”””

Douglas Miller


(Affirmative)

5.2 Editorial 3rd and 7th paragraph repeat same information. Merge these into one paragraph

Douglas Miller


(Affirmative)

5.2 Technical There should be a hard limit on annular space width. Otherwise at what point does double containment become single containment as the spilled liquid surface area gets large?

Maximum 6m annular space should be a SHALL rather than a SHOULD.

Douglas Miller


(Affirmative)

5.3 Editorial The standard should focus on requirements and today’s rules.

Eliminate phrases like: “more often than not”, “ it is more conventional to”, “historically”.

Douglas Miller


(Affirmative)

5.3 Editorial 4th and 9th paragraphs are both on the meaning of primary liquid containment

Merge 4th and 9th paragraphs.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Douglas Miller


(Affirmative)

5.3 Editorial 7th and 11th paragraphs are both on outer tank vapor barriers.

Merge 7th and 11th paragraphs

Douglas Miller


(Affirmative)

5.3 11th paragraph

Technical Need to generalize since outer liquid container could be metal while still addressing behavior if it is lined concrete.

Under inner tank leakage (emergency conditions), the SECONDARY LIQUID CONTAINER will be exposed to cryogenic conditions. SECONDARY LIQUID CONTAINERS shall be designed to be LIQUID tight in this condition but some product VAPOR permeation through the secondary liquid container is acceptable in this case. This situation of liquid tight with vapor permeation can be expected in the case of a prestressed concrete secondary liquid container with a vapor barrier liner.

Douglas Miller


(Affirmative)

5.3 10th paragraph.

Editorial This is part of definition of full containment concept. Delete this. It’s not needed if a proper definition is placed at the start of the section.

Douglas Miller


5.3 12th paragraph

Technical This content should be left to ACI 376 Delete this paragraph.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Douglas Miller


(Affirmative)

5.4 Other Move most of this to appendix 5.4 could just say “The storage concept shall be selected by the PURCHASER based on an assessment of risks in which the characteristics of the storage concept are considered in the context of jurisdictional regulations and the plan for the overall facility. Guidance information on some implications of the various tank concepts on the assessment of risks is provided in Appendix XX.”

Douglas Miller


(Affirmative)

5.4.1 Editorial Improvements to the text of 5.4.1 (though it should be in an appendix are as follows:

1st paragraph: “REFRIGERATED LIQUIFED GAS FACILITIES CAN in the event of an upset or emergency release GASES that present and significant threat ……”

6th paragraph: Refer to API 625 Appendix A

Douglas Miller


(Affirmative)

5.4.2, 4th paragraph

Editorial Improvements to the text of 5.4.2 (though it should be in an appendix are as follows:

This seems to be statement of acceptance criteria that seems very buried. Merge it in to 1st paragraph as follows: “The hazards assessment shall consider the requirements of national and local authorities and the influence of external, internal and environmental hazards. The risk assessment shall demonstrate that the risks to property and life are acceptable




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

both inside and outside the plant boundary”

Douglas Miller


(Affirmative)

6 Editorial Why not- phrase this so that subsections 6.3, 6.4 and 6.5 are mentioned IN ORDER.

This section provides guidance for design of refrigerated tank systems to meet the performance criteria prescribed in 6.3 when subjected to applicable normal and abnormal design loads defined in 6.4. Guidelines for performing the seismic analysis are presented in 6.5

Douglas Miller


(Affirmative)

6.2 Editorial Title of this section should not be so narrow. We are addressing more.

Replace “Maximum Design Liquid Level” with “Tank Volumes and Liquid Levels”

Douglas Miller


(Affirmative)

6.2 Editorial The “tank shell” is not such a specific term in the context of our tanks systems.

Replace “tank shell” with “primary liquid container”.

Douglas Miller


(Affirmative)

6.2 Technical That we must “design to the design liquid level” does not need to be said since it is self-evident. We SHOULD be saying something about how the design liquid level is to be set. This should also address levels related to overfill protection. Perhaps tie into API RP 2350.

Douglas Miller


Figure 6-1 Technical The title “Operating Freeboard” is not correct since the dimension is not tied to an operating level.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative)

Douglas Miller


(Affirmative)

6.3 Editorial The word “erection” does not sound right in the context of Performance Criteria.

Maybe we should say “Completed tank systems in accordance with this standard shall satisfy….”

Douglas Miller


(Affirmative)

6.3.1 2nd paragraph

Editorial seems to have unnecessary extra words. “The primary vapor container shall be vapor tight during normal operation”

Douglas Miller


(Affirmative)

6.3.6 Editorial We should consistently use the defined terms from section 3 whenever applicable

1st bullet: Replace “… secondary liquid containment tanks” with “… secondary liquid containers”.

2nd bullet: Replace “Primary vapor containers subjected primarily to product temperatures ” with “Refrigerated temperature roofs and suspended decks”.

3rd bullet: Replace “Primary vapor containers subjected primarily to ambient temperatures” with “Warm vapor containers”.

4th bullet: OK as-is

5th bullet: Replace “ primary vapor container…” with “warm vapor container”.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Douglas Miller


(Affirmative)

6.3.6 5th bullet

Editorial Structure of writing should be same of previous items where the DOT defines the applicable componant and the DASH defines the applicable design temperature.

DOT Local areas of the WARM vapor container (e.g. process nozzle thermal distance piece connections to the vapor container) which may be subjected to temperatures below ambient conditions:

DASH MINIMUM design temperatures for these locations shall take this local cooling effect into consideration.

Douglas Miller


(Affirmative)

6.3.8 Editorial “Liquifed Gas” does not need to be capitalized. Actually the words can be deleted. They are unnecessary.

Douglas Miller


(Affirmative)

6.3.10 Editorial Move the final sentence about sloshing waves into the opening paragraph of the section. That way you get the three references all together: 6.4.2 for loads, 6.5.9 for sloshing, 6.5.10 for sliding.

Douglas Miller


(Affirmative)

6.4 Technical We should clarify that certain loads may not always be applicable

“Shrinkage and Creep-Induced Loads FOR CONCRETE CONTAINER”

“Loads from liquid spill condition (FOR DOUBLE AND FULL CONTAINMENT TANK SYSTEMS)”

“Loads based on a risk




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

assessment such as fire, blast, external missile etc. (WHEN SPECIFIED BY PURCHASER)“

Douglas Miller


(Affirmative)

6.5.8 Technical This section implies that high level alarms are optional, but 7.4.1 makes them mandatory

Delete the opening “if” phrase.

Douglas Miller


(Affirmative)

7.0 Editorial Too many plural words hurt readability. “considerations” is the subject of the sentence. Other words are modifiers and I think don’t need to be made plural.

“Accessory and appurtenance considerations ….”

Douglas Miller


(Affirmative)

7.2.1.3.c Editorial Readablilty of this section is still poor. Too much back and forth between prohibitions, waivers of probitions, and regulations overruling waivers. Let me see if I can improve this:

c. For double or full containment tanks, shell or bottom penetrations that breach the primary and secondary containment are not allowed except when all of the following additional requirements are met:

i The penetrations are specified by the Purchaser

ii No prohibition exists in applicable regulations (e.g. NFPA 59A).

iii A remote bund wall is provided in addition to the secondary containment that is




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

part of the tank system

iv In-tank valves are provided when storing flammable products Refer to 7.2.1.3(b)

Douglas Miller


(Affirmative)

7.3.1 Editorial Replace “code and standard” with “codes and standards”

Douglas Miller


(Affirmative)

7.3.3 Technical When air is drawn into tank due to rapid lowering of liquid level, doesn’t warm vapor or warm air go into the cold space regardless of whether the vacuum vents discharge air into dome space or if the air is ducted to under the suspended deck???

Require accounting for vapor contraction of warm to cold in any case.

Douglas Miller


(Affirmative)

7.3.3 Technical Replace “should be taken into consideration” with “shall be taken into consideration”

Douglas Miller


(Affirmative)

7.4.2 Editorial Readability of the exceptions to leak detection requirement is poor since it describes an exception to an exception. Better to state positive requirements when possible.

“A system for detecting leaks through the primary liquid container shall be provided for all double and full containment tanks. Such a system is required for double-wall single containment tanks only if specified by purchaser or if required by a result of a hazard study. The system shall be based on one of the following




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

systems….”

Douglas Miller


(Affirmative)

7.8 Editorial If purchaser specifies a spill collection system, the contractor needs to provide it, not just consider it.

Replace “shall be considered” with “shall be provided”.

Douglas Miller


(Affirmative)

8 Technical We still need to draft a tank system nameplate and data report.

Douglas Miller


(Affirmative)

12 Editorial Add section numbering to each paragraph

Douglas Miller


(Affirmative)

10.3.2 Editorial Section reference should be changed from 8.2.3 to 7.2.3.

Douglas Miller


(Affirmative)

10.5 Editorial Dual units are missing in two places.

Masaki Takahashi

IHI Inc.

5.3 Technical Where prestressed concrete outer tanks are selected vapor containment during normal service is achieved

Delete "polymeric vapor barrier" unless it is accepted by ACI376.




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative) through the incorporation of a warm temperature metallic or polymeric vapor barrier applied to the inside face of the concrete wall. Where metallic outer tanks are provided vapor tightness shall be assumed.

In the above paragraph, "polymeric vapor barrier" is mentioned.

I don't exactly remember if we discussed about "polymeric vapor barrier" in API625 task group.

Or is this addressed in ACI376?

Masaki Takahashi

IHI Inc.

(Affirmative)

6.3.2 Technical In the last paragraph, "the normal maximum liquid level" should be "the design liquid level"

Masaki Takahashi

IHI Inc.

(Affirmative)

6.3.4 Technical The boil-off rate, normally specified in percent per day of maximum normal operating volume assuming a pure product,

In the above sentence, still "maximum normal operating volume" is used.

Normally this is gross volume.

Change "maximum normal operating volume" to "gross volume"

Masaki Takahashi

IHI Inc.

(Affirmative)

9.3.3.3 Technical Test method listed in this section should be kings of example.

For instance, all test blocks may not be taken from the same production run as mentioned in "a.Blocks shall be selected from the same production run".

I would suggest to use "should" instead of "shall" in this section.

Masaki Takahashi

IHI Inc.

10.5 Technical Cool down rate shown in this section looks a little conservative in comparison with current common practice.

The cool down rate for the primary liquid container should be controlled to an average of




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

(Affirmative) 9.0º F/h (5º C/h) but should not exceed 18º F/h (10º C/h).

Neven Krstulovic-Opara

Ove Arup & Partners

(Negative)

4.1 Technical 4.1 – General – Does the statement in the second sentence (“The contractor shall be responsible for the design, supply, fabrication, construction, inspection and testing of the tank.”) limit us only to EPC type of contracts?

Remove the statement and refer to " as specified by the owner".


Ove Arup & Partners

(Negative)

3.2.2, 3.2.12, 3.2.15

Technical 3.2.2 – Add requirement that a single containment tank must be liquid tight, as is the case for double containment tanks (3.2.3) and Full containment tanks (3.2.4).

3.2.12 – Freeboard – Define acronyms “OLE,” “CLE” and “ALE” the first time they are used – which is paragraph 3.2.12.

3.2.15 - Vapor Barrier – Vapor barrier should also prevent exit of any product vapor.

please see above


Ove Arup & Partners

(Negative)

5.1, 5.2, 5.3 Technical 5.1 – Single Containment:

a) Define that the single containment tank must be liquid tight, as is the case with full containment tanks (5.3).

b) Remove the first sentence on page 14 (“Penetrations below liquid level through the sides and bottom of the primary liquid and primary vapor barriers are permitted.”) Tank penetrations below the liquid level are not allowed for double (2nd sentence in the 3rd paragraph of section 5.2, page 16) and full containment tanks (e.g., item C in 7.2.1.3). Therefore,

Plkease see above




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

penetrations should not be allowed for single containment tanks.

c) Sketches of various single containment concepts should also present cases when the primary tank is made of concrete.

5.2 – Double Containment:

a) Define that both the primary and the secondary tanks must be liquid tight, as is the case with full containment tanks (5.3).

b) Sketches of various double containment concepts should also present cases when the primary tank is made of concrete.

5.3 – Full Containment:

a) 3rd and 4th line of the 3rd paragraph on page 18 - Remove “and retain the complete liquid contents.” This requirement:

• is not used in definitions of the single and the double containment in this document, and

• is not used if full containment definitions by other relevant national/international documents

b) Last sentence in the 3rd paragraph on page 18 - Remove the sentence “The outer tank shall be erected at a maximum distance from the inner wall of 6 feet where provided insulation is retained in this annular space.” There doesn’t seem to be a valid reason for limiting the annular space width.

c) 2nd and 3rd line of the 4th paragraph on




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

page 18 - Remove “and capable of retaining the complete liquid contents.” This requirement:

• is not used in definitions of the single and the double containment in this document, and

• is not used if full containment definitions by other relevant national/international documents

d) 3rd line of the 7th paragraph on page 18 - Remove “applied to the inside face of the concrete wall.” The vapor/moisture barrier can also be applied (i) within the wall or (ii) on the outside face of the wall.

e) Last line on page 18 and the 1st line on page 19 – Remove sentence “The outer tank shall be erected at a maximum distance from the inner wall of 6 ft.” There doesn’t seem to be a valid reason for limiting the annular space width.

f) 2nd paragraph on page 19 – Remove the entire paragraph. This discussion is outside the scope of a Standard document and furthermore is not correct. For instance, refrigerated full-containment, unlined all-concrete tanks have been used for storage of refrigerated liquefied gases (e.g., LOX). Furthermore, the same was not discussed in the case of single containment (section 5.1) and double containment (section 5.2) tanks.

g) Insert “material of the secondary concrete tank” so that the sentence reads: “Under inner tank leakage (emergency conditions), the material of the secondary concrete tank vapor barrier material will be exposed to cryogenic conditions.”

h) 2nd line in the 5th paragraph on page 19 - Insert “outer tank” so that the sentence reads: “For certain low temperature products such as methane significant design issues arise at monolithically connected outer tank base to wall joints due to the




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

mechanical restraint offered by the base.”

i) Sketches of various full containment concepts should also present cases when the primary tank is made of concrete.


Ove Arup & Partners

(Negative)

5.4 Technical 5.4 – Guidance and selection of Storage Concepts - Remove this section or fully re-write it. Currently the section focuses on Risk Analysis related failure scenarios and issue related to site selection, dispersion analysis, radiation analysis, etc., instead on the selection of a storage tank systems – which the title of the section indicates.

Please see above


Ove Arup & Partners

(Negative)

3.2.2 Technical Add requirement that a single containment tank must be liquid tight, as is the case for double containment tanks (3.2.3) and Full containment tanks (3.2.4).


Ove Arup & Partners

(Negative)

3.2.12 Editorial Freeboard - Define acronyms "OLE," "CLE" and "ALE" the first time they are used - which is paragraph 3.2.12.


Ove Arup & Partners

(Negative)

3.2.15 Technical Vapor Barrier - Vapor barrier should also prevent exit of any product vapor.


Ove Arup &

5.1 Technical Define that the single containment tank must be liquid tight, as is the case with full containment tanks (5.3).

Remove the first sentence on page 14 ("Penetrations page 46 of 49




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Partners

(Negative)

below liquid level through the sides and bottom of the primary liquid and primary vapor barriers are permitted.") Tank penetrations below the liquid level are not allowed for double (2nd sentence in the 3rd paragraph of section 5.2, page 16) and full containment tanks (e.g., item C in 7.2.1.3). Therefore, penetrations should not be allowed for single containment tanks.

Sketches of various single containment concepts should also present cases when the primary tank is made of concrete.


Ove Arup & Partners

(Negative)

5.2 Technical Double Containment:

Define that both the primary and the secondary tanks must be liquid tight, as is the case with full containment tanks (5.3).

Sketches of various double containment concepts should also present cases when the primary tank is made of concrete.


Ove Arup & Partners

(Negative)

5.3 Technical 5.3 - Full Containment:

3rd and 4th line of the 3rd paragraph on page 18 - Remove "and retain the complete liquid contents." This requirement:

is not used in definitions of the single and the double containment in this document, and

is not used if full containment definitions by other relevant national/international documents




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

Last sentence in the 3rd paragraph on page 18 - Remove the sentence "The outer tank shall be erected at a maximum distance from the inner wall of 6 feet where provided insulation is retained in this annular space." There doesn't seem to be a valid reason for limiting the annular space width.

2nd and 3rd line of the 4th paragraph on page 18 - Remove "and capable of retaining the complete liquid contents." This requirement:

is not used in definitions of the single and the double containment in this document, and

is not used if full containment definitions by other relevant national/international documents

3rd line of the 7th paragraph on page 18 - Remove "applied to the inside face of the concrete wall." The vapor/moisture barrier can also be applied (i) within the wall or (ii) on the outside face of the wall.

Last line on page 18 and the 1st line on page 19 - Remove sentence "The outer tank shall be erected at a maximum distance from the inner wall of 6 ft." There doesn't seem to be a valid reason for limiting the annular space width.

2nd paragraph on page 19 - Remove the entire paragraph. This discussion is outside the scope of a Standard document and furthermore is not correct. For instance, refrigerated full-containment, unlined all-concrete tanks have been used for storage of refrigerated liquefied gases (e.g., LOX). Furthermore, the same was not discussed in the case of single containment (section 5.1) and double containment (section 5.2) tanks.

Insert "material of the secondary concrete tank" so that the sentence reads: "Under inner tank leakage (emergency conditions), the material of the secondary




Date: May 18, 2023

1 2 3 4 5 6

Voter Name(Vote)


Type of Comment


Comment Resolution

concrete tank vapor barrier material will be exposed to cryogenic conditions."

2nd line in the 5th paragraph on page 19 - Insert "outer tank" so that the sentence reads: "For certain low temperature products such as methane significant design issues arise at monolithically connected outer tank base to wall joints due to the mechanical restraint offered by the base."

Sketches of various full containment concepts should also present cases when the primary tank is made of concrete.


Ove Arup & Partners

(Negative)

5.4 Technical 5.4 - Guidance and selection of Storage Concepts - Remove this section or fully re-write it. Currently the section focuses on Risk Analysis related failure scenarios and issue related to site selection, dispersion analysis, radiation analysis, etc., instead on the selection of a storage tank systems - which the title of the section indicates.


Documents

CommentsOn - My Committeesmycommittees.api.org/standards/cre/scast/Meeting Materials/Spri… · Web view(Affirmative) 6.2 Technical That we must “design to the design liquid level”