Transcript SPCC Tank Integrity Testing - Thompson Environmental

Tank Consultants, Inc.
4333 West 21st Street
Tulsa, Oklahoma 74107-3444
918-583-3968 Telephone
918-583-3966 Fax
www.tank-consultants.com
SPCC Tank Integrity Testing
• Presented By: Kevin Kupitz
Who has to test their tanks?
• If you have a facility with
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an aggregate oil storage
capacity of 1320 gallons
you must inspect all
containers 55 gallons and
above.
Applies to
owners/operators that
use oil. This would
include storage capacity
of operating equipment.
What type of facilities does this
include?
• SPCC States:
• “oil of any kind or in any form, including but not
limited to: fats, oils, or greases of animal, fish
or marine mammal origin; vegetable oils,
including oils from seeds, nuts, fruits, or kernels;
and other oils and greases, including petroleum,
fuel oil, sludge, synthetic oils, mineral oils, oil
refuse, or oil mixed with waste other than
dredged oil”
Facilities such as:
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Marinas
General processing
Refineries
Pipelines
Terminals
Chemical plants
Many other facilities
SPCC plan review
• The original SPCC regulation was effective
beginning January 10, 1974
Revisions
• The new revision requires
•
owner/operators to test
above ground containers
for integrity on a periodic
basis.
Most facilities should
have a plan already that
only requires revising.
Schedule for the new plan
• Must have your SPCC plan amended by
August 17, 2004.
• Must implement your plan by February 18,
2005.
Why should I inspect my tanks?
Why should I inspect my tanks?
• To protect our
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environment.
EPA will audit facilities
as necessary.
ND just fined 17
companies for over
$400,000.00.
Oxychem penalty of
$137,500.00
Issues
• Incomplete plan.
• Failure to inspect tanks, valves, piping and
appurtenances.
• Failure to conduct integrity testing
• Lack of secondary containment for tanks.
• Inadequate secondary containment.
What does an O/O have to do to
comply?
• SPCC does not refer to or mandate the use of
any industry standard as related to tank
inspection. Although it states:
• “Consider the use of all relevant measures,
including the use of industry standards, as a way
to implement those measures.”
• “The decision in every case as to the
applicability of any standard will be one for the
P.E.”
What industry standards do we
need to consider?
• API-653
– Written by tank builders, owners/operators and repair
companies
– For self regulation rather than government regulation
• STI SP001-03 was written by
– Tank builders
– At the request of the EPA
API-653 applies to:
• API-650 “Welded Steel
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Tanks for Oil Storage”
API-12C, the predecessor
to API-650
Any unknown standard
API-653 Certified
Inspector
STI SP001-03 applies to:
• Tanks SHOP built to any
nationally recognized
standard
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UL-142, 2085 and 2244
API-650 Appendix J
API-12F
SwRI 97-04, 93-01
• <50,0000 gallon tanks.
• STI Trained Inspector.
What tests do we have to do to
comply?
• Perform periodic “Integrity Tests”.
• Evaluate field constructed containers for
Brittle Fracture during repairs, alterations
or change in service.
• Record keeping.
What constitutes an Integrity Test?
• SPCC states:
• “You must combine visual inspection with
another testing technique such as
hydrostatic testing, RT, UT, AE or another
system of non-destructive shell testing”.
• “Test each above ground container for
integrity on a regular schedule, and
whenever you make material repairs”.
What does this mean?
• The actual inspection can be in
accordance with STI SP001-03 or API-653
or a combination of both.
• Either way, the P.E. must sign off on the
inspection technique.
The tank inspection will be
determined by a few main variables
• SPCC states:
• “The frequency of and type of testing
must take into account container size and
design (such as floating roof, skid
mounted, elevated, or partially buried).”
Example tank inspection for Field
Erected Vertical Tank on Grade.
Example tank inspection for Field
Erected Vertical Tank on Grade.
• Monthly visual check by operator.
• 5 year external by a certified inspector by
VT and UT methods while the tank is full.
• 10 year internal inspection incorporating
VT, UT and/or MFL. Check tank bottom.
• As an option, the tank could be lifted
exposing all sides of the tank.
Vertical tank on Grade with Leak
Detection.
• Monthly visual check by the operator.
• 5 year external inspection by a certified
inspector with tank full of product.
• Internal inspection only when leaks are
found or the integrity is questioned by the
certified inspector.
Horizontal Tank with all Sides
Exposed.
Horizontal Tank with all Sides
Exposed.
• Monthly visual check by operator.
• Perform a 5 year external inspection with
the tank full of product.
• Perform thorough Ultrasonic (UT)
evaluation on the lower 60 degrees of the
tank.
• Perform UT scrubs on the heads of the
tank.
O/O with many tanks
O/O with many tanks
• Perform an Inventory/walk through
inspection.
• Prioritize tanks by condition and location.
• Plan what needs to be done for all tanks
to be “integrity tested”.
• Schedule the “integrity Test”.
Test Techniques
• Ultrasonic Thickness Testing (UTT)
• Magnetic Flux Leakage (MFL) Floorscan
• Ultrasonic (UT) Corrosion Scanning (Ascan)
• Magnetic Particle Testing (MT)
• Visual Examination (VT)
Ultrasonic Thickness Test
MFL Floorscan
Ultrasonic Corrosion Scanning
Visual Inspection
Holes from Soil Side Corrosion
Weeps
Conclusion
• Integrity Testing is accomplished by
collecting the important tank variables and
then determining what industry inspection
standards make sense and then apply
them.
• Your P.E. must approve them into the
plan.
Just remember, there are more
painful things in life!