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 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: • 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? • To protect our 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 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 • 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. • 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. • 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 • 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 (A-scan) • Magnetic Particle Testing (MT) • Visual Examination (VT)
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.