Shop-Fabricated Tank InspectionShop-Fabricated Tank Inspection

Chris BashorChris BashorMinnesota Pollution Control AgencyMinnesota Pollution Control Agency

June, 2001June, 2001

Shop-Fabricated Tank InspectionShop-Fabricated Tank Inspection

History of States-EPA Workgroup InterestHistory of States-EPA Workgroup Interest STI Standard SP001-00STI Standard SP001-00 Comparison with API 653Comparison with API 653 Relevance of SP001-00 to States and EPARelevance of SP001-00 to States and EPA IssuesIssues ConclusionsConclusions

History of States-EPA Workgroup InterestHistory of States-EPA Workgroup Interest EPA identifies SPCC need: no industry standard EPA identifies SPCC need: no industry standard

for inspection of small tanksfor inspection of small tanks Steel Tank Institute develops draft standardSteel Tank Institute develops draft standard Workgroup reviews draft standard at May 2000 Workgroup reviews draft standard at May 2000

meeting and submits commentsmeeting and submits comments Final STI standard: September 2000Final STI standard: September 2000

STI Standard SP001-00STI Standard SP001-00

Steel Tank InstituteSteel Tank Institute ApplicabilityApplicability Periodic inspectionsPeriodic inspections Certified inspectionsCertified inspections

Steel Tank InstituteSteel Tank Institute

www.steeltank.comwww.steeltank.com Contact: Dana Schmidt 847-438-8265Contact: Dana Schmidt 847-438-8265 Paper copies available for $35Paper copies available for $35 Electronic version was emailed to states Electronic version was emailed to states

ApplicabilityApplicability

Shop-fabricated ASTs (up to 50,000 gal)Shop-fabricated ASTs (up to 50,000 gal) Built to national standard (e.g. UL142)Built to national standard (e.g. UL142) Storage of “noncorrosive, stable, flammable, and Storage of “noncorrosive, stable, flammable, and

combustible liquids having specific gravity not combustible liquids having specific gravity not exceeding that of water”exceeding that of water”

Includes foundation and vents, but not piping Includes foundation and vents, but not piping

Applicability (cont)Applicability (cont)

Can be used for double-walled tanksCan be used for double-walled tanks Elevated or not, horizontal or vertical, manway Elevated or not, horizontal or vertical, manway

or notor not MN believes standard is applicable for the most MN believes standard is applicable for the most

part to tanks of these types storing most other part to tanks of these types storing most other liquids, even if non-standard constructionliquids, even if non-standard construction Corrosive liquids need special attention Corrosive liquids need special attention

Periodic InspectionsPeriodic Inspections

Qualifications: owner or any employee (no Qualifications: owner or any employee (no training)training)

Monthly: water draw; DW interstitial space; Monthly: water draw; DW interstitial space; pipe connectionspipe connections

Quarterly: “walk-around” for damage, external Quarterly: “walk-around” for damage, external coating, cleaning, repairs, ventscoating, cleaning, repairs, vents

Periodic Inspections (cont)Periodic Inspections (cont)

Annually: proper drainage, foundationAnnually: proper drainage, foundation Other: recordkeeping checklists, diagrams, Other: recordkeeping checklists, diagrams,

maintenance info, referencesmaintenance info, references

Certified InspectionsCertified Inspections

Qualifications:Qualifications: API 653 certifiedAPI 653 certified STI certifiedSTI certified

Frequency: every 10 years, or more often based Frequency: every 10 years, or more often based on calculated minimum remaining wall thicknesson calculated minimum remaining wall thickness

Certified Inspections (cont.)Certified Inspections (cont.)

Procedures:Procedures: All visual per periodic checklistsAll visual per periodic checklists Pressure test for tightnessPressure test for tightness Shell inspectionShell inspection

Certified Inspections (cont.)Certified Inspections (cont.)

Shell inspection methods depend on whether tank Shell inspection methods depend on whether tank is single or double-walled, elevated or not, has is single or double-walled, elevated or not, has manway or not, has cathodic system or notmanway or not, has cathodic system or not

Procedures include:Procedures include: Ultrasonic thickness testing (criteria given)Ultrasonic thickness testing (criteria given) Visual inspection (minimal criteria given)Visual inspection (minimal criteria given) ASTM G 158ASTM G 158 NACE RP-0285NACE RP-0285

Comparison with API 653Comparison with API 653

In general, SP001-00 is much less rigorousIn general, SP001-00 is much less rigorous No standards for repairs or alterationsNo standards for repairs or alterations No provisions for upgrading non-UL142 to No provisions for upgrading non-UL142 to

acceptable conditionacceptable condition All in all, however, generally appropriate to All in all, however, generally appropriate to

level of risk involvedlevel of risk involved

Relevance of SP001-00 to States and EPARelevance of SP001-00 to States and EPA MinnesotaMinnesota Other statesOther states EPAEPA

MinnesotaMinnesota

SF tanks at SF tanks at smallsmall facilities: facilities: Rules require equivalent of periodic but not certifiedRules require equivalent of periodic but not certified Rule change would be needed for certifiedRule change would be needed for certified

SF tanks at SF tanks at majormajor facilities: facilities: Permits do not now require inspection of SF tanksPermits do not now require inspection of SF tanks Re-permitting will require SP001-00 starting 2001Re-permitting will require SP001-00 starting 2001

MinnesotaMinnesota

Enhancements to SP001-00 to be required:Enhancements to SP001-00 to be required: Walk-around inspection Walk-around inspection monthlymonthly Periodic records kept for Periodic records kept for threethree years, certified report kept years, certified report kept

for for life of tanklife of tank Records and reports must Records and reports must documentdocument repairsrepairs needed and needed and

mademade Repairs recommended must be Repairs recommended must be made unless waivedmade unless waived Certified report must include UT and other Certified report must include UT and other datadata

MinnesotaMinnesota

So far, no facilities seem to be using SP001-00So far, no facilities seem to be using SP001-00 Owners waiting for state/federal requirement?Owners waiting for state/federal requirement?

Some consultants now use API 653 for SF tanksSome consultants now use API 653 for SF tanks Consultants who are API 653 certified will be in Consultants who are API 653 certified will be in

a position to offer lower cost SP001-00 certified a position to offer lower cost SP001-00 certified inspectionsinspections

Other StatesOther States

WisconsinWisconsin Working with STI to offer inspector certificationWorking with STI to offer inspector certification

PennsylvaniaPennsylvania Has its own integrity inspection criteriaHas its own integrity inspection criteria

Other states?Other states?

EPAEPA

Current SPCC requires “periodic integrity Current SPCC requires “periodic integrity testing”, gives examples of visual and N-D shell testing”, gives examples of visual and N-D shell thickness (UT) testing (112.7(e)(2)(vi))thickness (UT) testing (112.7(e)(2)(vi))

SPCC revisions (when final) will be more SPCC revisions (when final) will be more specific about frequency and technique, and will specific about frequency and technique, and will specifically refer to SP001-00specifically refer to SP001-00

IssuesIssues

Standard has weaknessesStandard has weaknesses Availability of qualified inspectorsAvailability of qualified inspectors How to get the owner “into the program”How to get the owner “into the program” How to get that first certified inspectionHow to get that first certified inspection

ConclusionsConclusions

On the whole, SP001-00 should prove valuableOn the whole, SP001-00 should prove valuable States and EPA can jointly have a positive States and EPA can jointly have a positive

influence on industry standards, e.g. STI, API influence on industry standards, e.g. STI, API (new RBI standard), Fertilizer Institute(new RBI standard), Fertilizer Institute

Would like to see more partnering with industry Would like to see more partnering with industry groups on AST standards, especially with APIgroups on AST standards, especially with API