Transcript Integrity Testing - Southern Section Air & Waste Management

Integrity Testing of
Aboveground Storage
Tanks
2012 Southern Section AWMA
Annual Meeting and Conference
Andrew Covington, P.E.
Presentation Outline
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Introduction
About Eco-Systems, Inc.
What Is Integrity Testing?
Why Should I Have My Storage Tanks Inspected?
SPCC Regulations
Baseline Conditions
Regulations/Industry Standards
STI SP001
Hybrid Inspection Program
Environmental Equivalence
Other Considerations
Regulatory Deadline
Eco-Systems, Inc. Services
Questions
Introduction
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Andrew Covington, P.E.
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Professional Engineer
MS, AL, GA, LA, TX
Environmental/Petroleum Engineer
STI Certified Inspector
30 Years of relevant Experience
Expertise
 Permitting & Compliance
 Air Quality
 SPCCs & SWPPPs
About Eco-Systems, Inc.
Full Service Environmental Consulting
Firm
 Service Areas:
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Permitting & Compliance,
Natural Resources,
Remediation,
Planning, and
Engineering & Construction
What Is An SPCC?
Federal regulation that requires a spill
prevention control and countermeasure (SPCC)
plan be in place.
 Designed to detect and prevent oil leaks, spills,
or other potential integrity or structural issues
before they can result in a discharge of oil to
navigable waters of the U.S.
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What Is Integrity Testing?
A test performed to determine the useful life of
a Storage Tank.
 Visual Inspection is an accepted integrity testing
technique.
 Non-destructive type shell testing (Hydrostatic
Testing, Radiographic Testing, Ultrasonic
Testing, Acoustic Emissions Testing, etc.).
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Why Should I Have My
Storage Tanks Inspected?
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Workplace Safety Considerations
Protection of the Environment
Industry Standards
Good Engineering Practices
Regulatory Requirements
Purpose of SPCC
and tank integrity
testing?
SPCC Regulations
40 CFR Part 112.8 (C) 6
Test or inspect each aboveground container for
integrity on a regular schedule and whenever
you make material repairs.
 You must determine, in accordance with
industry standards, what are the appropriate
qualifications for personnel performing tests
and inspections, the frequency, and type of
testing and inspections.
 Take into account container size, configuration,
and design.
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SPCC Regulations
40 CFR Part 112.8 (C) 6
You must inspect the container's supports and
foundations.
 You must inspect the outside of the container
frequently for signs of deterioration, discharges,
or accumulation of oil inside diked areas.
 You must keep complete records.
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SPCC Regulations
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Testing on a ‘regular schedule’ means testing
per industry standards or at a frequency
sufficient to prevent discharges. Whatever
schedule the P.E. selects must be documented in
the Plan.
SPCC Regulations
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P.E. may choose to develop an inspection and
testing program for the facility’s shop-built
tanks in accordance with
◦ STI SP001,
◦ API 653, or
◦ Hybrid Program
Industry Standards
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Steel Tank Institutes (STI) SP001
American Petroleum Institute (API) 653
National Fire Protection Association Fire Code
(NFPA 30)
Local Fire Code(s)
API 575 Atmospheric and Low Pressure Tanks
API 570 Piping Inspection Code
STI SP001
Standard For The Inspection Of Aboveground
Storage Tanks (Sept 2011, 5th Edition)
 Section 1.2 states that SPOO1 standards are
minimum requirements.
 Applies to:
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◦ Aboveground Storage Tanks.
◦ Storing Stable, Flammable, & Combustible Liquids at
Atmospheric Pressure and having a Specific Gravity
less than 1.0.
◦ Operating Ambient Temperatures up to 200 Deg F.
STI SP001
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At a minimum, the following tank components shall be
inspected (as applicable):
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Primary tank
Secondary tank
Tank supports
Tank anchors
Tank foundation and external supports
Tank gauges and alarms
Insulation covering
Tank appurtenances
Normal vents
Emergency vents
Release prevention barriers
Spill control systems
STI SP001
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Tank Categories:
◦ Category 1
 Secondary Containment
 Continuous Release Detection Method (CRDM)
 (Example - Elevated Tank where all sides of the tanks can
be inspected except at the supports)
◦ Category 2
 Secondary Containment
 No CRDM – (Example - Tank shell in contact with soil)
◦ Category 3
 No Secondary Containment
 No CRDM
STI SP001
STI SP001
STI SP001
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Inspection Of Field-Erected ASTS (Appendix B)
STI SP001
Periodic AST Inspections
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Conducted by Owner’s Inspector
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The personnel performing these inspections
shall be knowledgeable of storage facility
operations, the type of AST and its associated
components, and characteristics of the liquid
stored. (4.1).
STI SP001 Formal External
and Internal Inspections
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Conducted by Certified Tank Inspector (4.2)
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A Certified Tank Inspector shall be certified by
one or more of the following:
◦ API Standard 653 Authorized Inspector Certification
with STI SP001 Adjunct Certification.
◦ STI Certified SP001 AST Tank System Inspector.
◦ Additional certifications as may be required by
individual states or other governing bodies.
STI SP001
Suitability for Continued Service (10.0)
 Next formal internal inspection or the next
formal external inspection, as applicable, may
exceed the interval listed in STI SP001 (Table
5.5), if the corrosion rates allow and as
determined by P.E.
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STI SP001
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Other Tank Damage (10.3)- An AST requires
evaluation by an experienced engineer or tank
manufacturer to determine if further action is
needed if tank subjected to damage caused by
the following conditions :
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Fire
Natural disaster
Excessive Settlement
Overpressure
Damage from Cracking
STI SP001
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Recordkeeping (11)
◦ Retain each AST Record for the life of the AST.
◦ Retain each Monthly Inspection Checklist for at least
36 months.
◦ Retain each Annual Inspection Checklist for at least 36
months.
◦ Retain each Portable Container Monthly Inspection
Checklist for at least 36 months.
◦ Retain all Certified Inspection Reports for the life of
the AST.
Baseline Conditions
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ASTs With Known Baseline Conditions
◦ Shell thickness and
◦ Corrosion rates
Only when the baseline is known, an inspection
and testing program can be established on a
regular schedule as per Industry Standards.
Baseline Conditions
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ASTs With Unknown Baseline Conditions
◦ For ASTs baseline conditions are not known,
◦ A regular integrity testing program cannot be
established.
◦ P.E. must describe an interim schedule in the SPCC
Plan.
Hybrid Inspection Program
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The P.E. may use industry standards, along
with other good engineering principles, to
develop a customized inspection and testing
program for the facility.
Environmental Equivalence
◦ 40 CFR 112.7(a)(2) – Allows deviations from some
requirements when the owner provides equivalent
environmental protection by some other means of spill
prevention, control, or countermeasure.
Environmental Equivalence
Petroleum Marketers Association of America
(PMAA) SETTLEMENT LANGUAGE:
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Well-designed shop-built containers with a
shell capacity of 30,000-gallons or less
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Visual inspection plus elevation of a shopbuilt container and makes all sides of the
container, including the bottom, visible during
inspection.
Environmental Equivalence
PMAA SETTLEMENT LANGUAGE:
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Visual inspection with placement of a barrier between
the container and the ground, designed and operated in
a way that ensures that any leaks are immediately
detected.
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P.E. should begin by consulting appropriate industry
standards, such as those listed in Steel Tank Institute
Standard SP001 and API Standard 653.
Environmental Equivalence
PMAA SETTLEMENT LANGUAGE:
 P.E. may wish to consult industry standards such
as Underwriters Laboratory 142 or API Standard
650, Appendix J.
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Where a facility is considering environmental
equivalence approach for containers resting on the
ground, or presents risks for corrosion, the facility
should first evaluate the condition of the container
in accordance with good engineering practices,
including
seeking
expert
advice,
where
appropriate.
Other Considerations
 NFPA
30
 Local Ordinances
Regulatory Deadline
 Certain
facilities were required to comply
by November 10, 2011.
Eco-Systems, Inc. Services
 SPCC
Plan Review and Update
 Integrity Testing Program Set Up
 STI SP001 Certified Tank Inspections
 Consulting
Tank You!!!
Questions???
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Thank You…..