Dana Schmidt, PE

STI/SPFA

Steel Tank Institute

AST Inspections

Agenda

Brief review of SPCC Rule

SPCC relevance to small tanks and small facilities.

SP001 Standard for Inspection of Aboveground Storage Tanks

overview

SP001 5th Edition changes

SP031 Standard for Repair of Shop-Fabricated Storage Tanks

overview

Spill Prevention Control and Countermeasure (SPCC) rule 40 CFR part 112

Requires facilities to develop and implement SPCC Plan: Operating procedures to

Prevent an oil discharge; Control measures to prevent an

oil discharge from entering navigable waters; and

Countermeasures to contain, clean up, and mitigate the effects of any oil discharge that affects navigable waters

What is SPCC

A facility starting operation … Must …

On or before August 16, 2002 Maintain existing Plan.

Amend and implement revised Plan

by November 10, 2010

After August 16, 2002 through

November 10, 2010

Prepare and implement Plan by

November 10, 2010

After November 10, 2010

(excluding production facilities)

Prepare and implement Plan before

beginning operations.

After November 10, 2010

(production facilities)

Prepare and implement Plan within 6

months after beginning operations.*

Compliance Dates

Petroleum and Fuel Oils

Gasoline

Diesel

Lube oils

Aviation gasoline

Jet fuel

Naptha

Mineral spirits

Etc.

112.2

What is OIL?

Oil refuse

Oil mixed with wastes

Animal fats, oils, greases, vegetable oil (AFVO)

Mineral oils

Denatured ethanol

112.2

What is OIL?

1. If the total storage in containers (tanks)

a. Aboveground > 1320 gallons

b. Underground > 42,000 gallons

(and not subject to UST Rule)

2. It is not a transportation related facility

- which would fall under DOT

3. And there is a reasonable change of a discharge to waters

of the U.S. or adjoining shorelines

112.1

SPCC Rule Applicability

“Storage capacity” is defined as the shell capacity of the

container

Rated design capacity not the operational capacity

Moving the overfill does not decrease capacity

In containers with mixtures, total tank capacity is to be

used, not % oil

112.2

Container size determination

“Test/inspect each aboveground

container for integrity on a

regular schedule and whenever

material repairs are made.”

112.8(c)(6) and 112.12(c)(6)

Integrity Testing

• You must determine, in accordance with industry standards

• Appropriate qualifications for personnel performing tests and

inspections

• Frequency and type of testing and inspections which take into

account container size, configuration, and design, such as

containers that are:

• Shop built • Equipped with a liner

• Skid-mounted • Double walled

• Elevated • Partially buried

112.8(c)(6) and 112.12(c)(6)

Integrity Testing

SPCC Rule and Industry Standards § 112.3(d)(1)(iii) – SPCC

Plan requirements

in accordance with good

engineering practice,

including consideration of

applicable industry standards

that procedures for required

inspections and testing have

been established

Most PE’s realize industry

standards reduce liability

Allows for deviations from specific rule requirements

Owner/operator responsible to select, document and implement alternate measure

PE certifies the SPCC Plan in accordance with good engineering practices, including consideration of industry standards

112.7(a)(2)

Environmental Equivalence

• Owner/Operator:

– Identifies reason to deviate from rule requirement

– Determines an alternate, environmentally equivalent method of spill prevention, control, or countermeasure

– Goal is to achieve the same desired outcome

• SPCC Plan includes:

– Reason for nonconformance

– Detailed description of the alternate method and how it achieves equivalent environmental protection

• EPA Regional Administrator has authority to require an amendment of the Plan

What does EE involve?

Tier I qualified facility

10,000 gallons or less total

No container greater than

5,000 gallons

Meets reportable discharge

history criterion

Tier II qualified facility

10,000 gallons or less total

At least one container

greater than 5,000 gallons

Meets reportable discharge

history criterion

112.3(g)(2)

Qualified Facilities

112.3(g)(1)

Qualified Facilities

An optional choice for small facilities:

If… And… And.. Then…

A facility has

been subject to

SPCC for ten

years or more;

has an

aggregate

aboveground oil

storage capacity

of 10,000 gallons

or less;

had no reportable

discharges

during the ten

years prior to self-

certification;

the

owner/operator

can self-certify

his/her SPCC

Plan, without

review and

certification by a

licensed

Professional

Engineer (PE).

A facility has

been subject to

SPCC for less

than ten years;

(OR)

A facility is new;

has an

aggregate

aboveground oil

storage capacity

of 10,000 gallons

or less;

had no reportable

discharges since

becoming subject

to the SPCC

requirements;

Do not use environmentally equivalent measures,

Do not determine secondary containment to be

impracticable, AND

Do not need PE certification to comply with any rule

requirements

Qualified Facilities Limits

Appendix G

SPCC Plan template

Streamlined

Self-certified

No P.E. required

112.3(g)(1)

Tier I Qualified Facilities

Does not need to include:

Facility diagram

Facility description

Facility drainage

Facility transfer operations

Effluent treatment facility

Loading/unloading rack

Brittle fracture

• Self-certified (no P.E. required)

• Integrity testing per industry standards

112.3(g)(2)

Tier II Qualified Facilities

• “Hybrid Plans”

– A Tier II SPCC plan with PE certified sections

– Allows use of E.E. and impracability determinations for

containment so long as PE certified

112.3(g)(2)

Tier II Qualified Facilities

Standard for Inspection of Aboveground Storage

Tanks

Released Sept. 16, 2011

STI SP001 – 5th Edition

Inspection Based on Installation Type and

Risk to Environment

Tanks offering greatest

risk have significantly

more inspections

Tanks with less risk have

less inspections

SP001 Scope

Ambient up to 200°F

Atmospheric pressure

Facilities with a mix of tanks

Portable Containers (per SP001)

Closed top AST 55 U.S.

gallons or more and not

intended for fixed

installation

Fills void in industry for

inspection

Shop-Fabricated AST (per SP001)

Welded metal AST fabricated in a manufacturing facility

OR

An AST without a nameplate with a volume less than or equal to 50,000 U.S. gallons

Field-erected AST

(per SP001)

Welded metal AST erected on-site where it will be used.

Limited to a maximum shell height of 50 feet and a

maximum diameter of 30 feet

An AST without a nameplate that is more than 50,000 U.S.

gallons and a maximum shell height of 50 feet and a

maximum diameter of 30 feet

Spill Control

Prevent release of liquid to

environment

Includes:

Remote impounding

Secondary containment

dike/berm

Secondary containment

AST

Secondary containment

system

SP001 Key terms

Release Prevention Barrier (RPB)

Continuous Release Detection Method (CRDM)

Release Prevention Barrier (RPB)

Liquid containment

barrier

“Sufficiently

impervious”

Under the AST

Diverts leaks toward the

perimeter of the AST

where they can be easily

detected

Continuous Release Detection Method

(CRDM)

A means of detecting a release of liquid through

inherent design. It is passive because it does not require

sensors or power to operate. Liquid releases are visually

detected by facility operators.

Tank with Release Prevention Barrier

Secondary containment AST including double-wall ASTs

Elevated AST with release prevention barrier

Elevated tanks with spill control

now considered as CATEGORY 1

ELEVATED AST – an AST

which is not in contact with the

ground and which is raised

above the surface of the ground

or bottom of a vault using tanks

supports. An elevated AST

allows for a visual external

inspection of the bottom of the

primary tank. Examples of

elevated tanks are tanks

constructed on grillage or

grating, or tanks on supports.

Tanks with CRDM

Overfill Prevention additions

1.6 At a minimum, the

following tank components

shall be inspected (as

applicable):

Primary tank

Secondary tank

Tank supports

…

Overfill valves and alarms

OVERFILL PREVENTION -

Systems, procedures or devices

used to prevent liquid in ASTs

from running over or spilling out

of the AST during the filling

process. A person who is

physically present and in control

of a shutoff device during the

entire tank filling process is an

acceptable procedure to achieve

overfill protection.

Table 5.4

Example Categories Expanded

Category 1 – Secondary containment and

CRDM

Double-wall Tank Tanks in a

with Overfill Prevention Concrete Dike

Category 2 – Secondary

containment

Tanks in earthen dike

Dike prevents release due

to catastrophic tank release

only

Category 3

No Secondary

Containment

No RPB

Category 3

RPB, but no secondary containment

Initial Inspection 5.1 The owner shall use the AST’s type, size and type of

installation, corrosion rate and previous inspection history, if any,

to develop a schedule of applicable types of inspections for each

AST, per Table 5.5. The interval for the initial inspection shall

begin from the AST’s initial service date, if known. For the

purposes of this requirement, the initial service date is the date on

which liquid was first placed in the tank. If the initial service date

is not known, the owner shall be responsible for establishing and

documenting the initial service date.

Inspection Types • Owner Monthly/Annual Inspections

– Check operation of vents, coating, foundation

• Formal External Inspections

– Certified inspector, but no entry

• Leak Test

– Determine if AST is leaking.

• Formal Internal Inspections

– Entry into tank is necessary

for full assessment

Risk Matrix concept

Tank Size Category 1 Category 2 Category 3

Shop built tanks

0 - 1100 P P P, E&L(10)

1101 - 5,000

P P, E&L(10) [P, E&L(5), I(10)] or

[P, E(5) & L(2)]

5,001 - 30,000

P, E(20) [P, E(10)& I(20)] or

[P, E(5) & L(10)]

[P, E&L(5), I(10)] or

[P, E(5) & L(1)]

30,001 - 50,000

P, E(20) P, E&L(5), I(15) P, E&L(5), I(10)

Field erected P, E(5), I(10) P, E(5), I(10) P, E(5), I(10)

Portable containers

P P P **

More Risk

Mo

re R

isk

Owner’s inspections

Monthly and Annual

Containment area and foundation

Shell coating

Normal vents operation

Emergency vents operation

Tank level gauge

Interstitial space monitor

Overfill valves and alarms

Additions to checklists

Monthly Checklist

Tank valves

Overfill equipment

Ladder and platform

Yearly Checklist

Vents – components freely move

Anti-siphon, check, gate valves

Press. Regulator

Expansion relief

Solenoid valve

Fire / shear valve

Leak detectors

Filter / Strainer

Overfill and liquid level equipment

Labels and tags

Formal External and

Formal Internal Inspections

Performed by Qualified Tank Inspector

STI Trained and Certified

API 653 Adjunct Certified (with additional SP001 certification)

Formal External Inspections Containment area

Stairways, ladders

Normal vents

Emergency vents

Overfill alarms

Fire valves

UT of accessible areas, near

base of tank (internal

inspection if problems found)

Formal Internal Inspections

Check all external

inspection items

UT of entire tank bottom

elevated tanks do not

require entry

UT methods

UTT – point

measurements (15 points

per sq. ft.)

UTS – full scan if problems

found in UTT

STI Inspector Certification

Attend seminar

Pass exam

Visual acuity exam

5 year certification

Over 750 certified STI

inspectors

SP001 2012/2013

Certification dates

Baltimore, MD: December 10 – 14, 2012

Baltimore, MD: April 29-May 3, 2013

Baltimore, MD: August 19-13, 2013

More dates at www.steeltank.com

“Certification Programs”

Inspection Schedule/Table P–Periodic Inspection by Owner E-External Inspection by Certified Inspector I-Internal

Inspection L-Leak Test

Size, Gallons Category 1 Category 2 Category 3

Shop built tank

0 - 1100 P P P, E&L(10)

1101 - 5,000

P P, E&L(10) [P, E&L(5), I(10)] or

[P, E(5) & L(2)]

5,001 - 30,000

P, E(20) [P, E(10)& I(20)] or

[P, E(5) & L(10)]

[P, E&L(5), I(10)] or

[P, E(5) & L(1)]

30,001 - 50,000

P, E(20) P, E&L(5), I(15) P, E&L(5), I(10)

Field Erect Tank P, E(5), I(20) P, E(5), I(20) P, E(5), I(20)

Portable Containers

P P P **

Insulated AST

Remove insulation where moisture or product collects

If vapor barrier damaged, remove sections of insulation

Inspection Schedule/Table P–Periodic Inspection by Owner E-External Inspection by Certified Inspector I-Internal

Inspection L-Leak Test

Size, Gallons Category 1 Category 2 Category 3

Shop

built

tank

0 - 1100 P P P, E&L(10)

1101 -

5,000

P P, E&L(10) [P, E&L(5), I(10)]

or

[P, E(5) and L(2)]

5,001 -

30,000

P, E(20) [P, E(10)and I(20)]

or

[P, E(5) and L(10)]

[P, E&L(5), I(10)]

or

[P, E(5) and L(1)]

30,001 -

50,000

P, E(20) P, E&L(5), I(15) P, E&L(5), I(10)

Field Erect Tank P, E(5), I(20) P, E(5), I(20) P, E(5), I(20)

Portable

Containers

P P P **

UST as AST

Suitability for continued service MIC corrosion – Repair

immediately. Next inspection 2 years

Category 3 – less than 75% remaining, then repair. Next inspection 5 years

Category 2 – 3 in2 in a sq. ft. is less than 75% remaining, or less than 50%, then repair. Next inspection 5 years

Category 1 – 3 in2 in a sq. ft. is less than 50% remaining, or less than 25%, then repair. Next inspection 5 years

% Remaining

3”

MIC corrosion

Why Develop a Repair Standard?

• Provide recommendations for safe repair of tanks

• Companion standard STI SP001

• What do I do with a tank after it has been inspected?

– Can it be repaired?

– How can it be repaired?

What makes shop-fabricated tanks

different?

Shop-fabricated

Typical Bottom or Head

Field-erected

Typical Bottom

SP031 Standard Organization

1.0 Scope

2.0 Definitions

3.0 Safety Considerations

4.0 Personnel Qualifications - Repair and Inspection

5.0 Materials and Welding

6.0 Modifications

7.0 Repairs

8.0 Testing

Scope Aboveground Tanks

Flammable and Combustible

Atmospheric

Shop-fabricated carbon and stainless steel

Built to national standards

What is not included?

Underground tanks to be used aboveground

Field-erected tanks

Bolted or riveted tanks

Good engineering practice and experience

Scope

Tank Owner Responsibilities Adherence with codes, standards, and regulations

Responsible that individuals working on tanks can

understand and address the hazards

Repair or modification may impact Listing

Limited to tank wall, supports, connections, nozzles, manways

Does not cover attachments to tank such as catwalks, platforms, etc.

Safety

• The hazards associated with the cleaning, entry, inspection,

testing, maintenance or other aspects of ASTs are significant.

Safety considerations and controls should be established prior

to undertaking physical activities associated with ASTs.

• Each AST entry requires an Emergency Action Plan.

• NFPA and API Industry Standards

• OSHA requirements

• Minimum Entry Tests for O2, LEL, CO, H2S

Safety Hazards with Flammable and

Combustible Tanks

Fires

Explosions

Suffocation

Releases to the

Environment

SP031 Personnel Qualifications

Repair/Modify

Manufacturer of Labeled/Listed Tanks

ASME Section IX

AWS D1.1

Tester – experience with methods

Final Inspection STI SP001

API 653

Manufacturer of Labeled/Listed Tanks

Repairs at knuckle

Limited repairs in knuckle

area

Otherwise, replace the

bottom or head.

Shell Repairs

Lap weld patch

plates

Insert plates

Shape

Existing welds spacing

Modifications Section

New pipe connections

Reinforcing plate when

pipe >2”

Manways

Reinforcing plate when

below liquid level

New second bottom

Knuckle at bottom

Increase Shell Height

Anchor Chair Addition

Bottom Repairs

Testing Requirements

• Testing of all repairs and modifications required

• Significant repair examples (requires tank pressure test)

– Complete replacement of bottom

– Patch plate greater than 12 square feet

– Openings greater than 12 inches diameter

• Final inspection by SP001 inspector or tank manufacturer

Available in “Publications Index” at www.steeltank.com

SP001 and SP031 available together at a discounted price

Technical Questions – STI Engineer and Staff Liaison

Dana Schmidt

847-438-8265 ext 246

dschmidt@steeltank.com