1. Tank Consultants, Inc. 4333 West 21st Street Tulsa, Oklahoma 74107-3444 918-583-3968 Telephone 918-583-3966 Fax www.tank-consultants.com

2. SPCC Tank Integrity Testing Presented By: Kevin Kupitz Presented By: Kevin Kupitz

3. 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. 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. Applies to owners/operators that use oil. This would include storage capacity of operating equipment.

4. What type of facilities does this include? SPCC States: 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” “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”

5. Facilities such as: Marinas Marinas General processing General processing Refineries Refineries Pipelines Pipelines Terminals Terminals Chemical plants Chemical plants Many other facilities Many other facilities

6. SPCC plan review The original SPCC regulation was effective beginning January 10, 1974 The original SPCC regulation was effective beginning January 10, 1974

7. Revisions The new revision requires owner/operators to test above ground containers for integrity on a periodic basis. 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. Most facilities should have a plan already that only requires revising.

8. Schedule for the new plan Must have your SPCC plan amended by August 17, 2004. Must have your SPCC plan amended by August 17, 2004. Must implement your plan by February 18, 2005. Must implement your plan by February 18, 2005.

9. Why should I inspect my tanks?

10. To protect our environment. To protect our environment. EPA will audit facilities as necessary. EPA will audit facilities as necessary. ND just fined 17 companies for over $400,000.00. ND just fined 17 companies for over $400,000.00. Oxychem penalty of $137,500.00 Oxychem penalty of $137,500.00

11. Issues Incomplete plan. Incomplete plan. Failure to inspect tanks, valves, piping and appurtenances. Failure to inspect tanks, valves, piping and appurtenances. Failure to conduct integrity testing Failure to conduct integrity testing Lack of secondary containment for tanks. Lack of secondary containment for tanks. Inadequate secondary containment. Inadequate secondary containment.

12. 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: 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.” “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.” “The decision in every case as to the applicability of any standard will be one for the P.E.”

13. What industry standards do we need to consider? API-653 API-653 –Written by tank builders, owners/operators and repair companies –For self regulation rather than government regulation STI SP001-03 was written by STI SP001-03 was written by –Tank builders –At the request of the EPA

14. API-653 applies to: API-650 “Welded Steel Tanks for Oil Storage” API-650 “Welded Steel Tanks for Oil Storage” API-12C, the predecessor to API-650 API-12C, the predecessor to API-650 Any unknown standard Any unknown standard API-653 Certified Inspector API-653 Certified Inspector

15. STI SP001-03 applies to: Tanks SHOP built to any nationally recognized standard 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. <50,0000 gallon tanks. STI Trained Inspector. STI Trained Inspector.

16. What tests do we have to do to comply? Perform periodic “Integrity Tests”. Perform periodic “Integrity Tests”. Evaluate field constructed containers for Brittle Fracture during repairs, alterations or change in service. Evaluate field constructed containers for Brittle Fracture during repairs, alterations or change in service. Record keeping. Record keeping.

17. What constitutes an Integrity Test? SPCC states: 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”. “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”. “Test each above ground container for integrity on a regular schedule, and whenever you make material repairs”.

18. What does this mean? The actual inspection can be in accordance with STI SP001-03 or API-653 or a combination of both. 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. Either way, the P.E. must sign off on the inspection technique.

19. The tank inspection will be determined by a few main variables SPCC states: 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).” “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).”

20. Example tank inspection for Field Erected Vertical Tank on Grade.

21. Monthly visual check by operator. Monthly visual check by operator. 5 year external by a certified inspector by VT and UT methods while the tank is full. 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. 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. As an option, the tank could be lifted exposing all sides of the tank.

23. Vertical tank on Grade with Leak Detection. Monthly visual check by the operator. Monthly visual check by the operator. 5 year external inspection by a certified inspector with tank full of product. 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. Internal inspection only when leaks are found or the integrity is questioned by the certified inspector.

24. Horizontal Tank with all Sides Exposed.

25. Monthly visual check by operator. Monthly visual check by operator. Perform a 5 year external inspection with the tank full of product. 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 thorough Ultrasonic (UT) evaluation on the lower 60 degrees of the tank. Perform UT scrubs on the heads of the tank. Perform UT scrubs on the heads of the tank.

26. O/O with many tanks

27. Perform an Inventory/walk through inspection. Perform an Inventory/walk through inspection. Prioritize tanks by condition and location. Prioritize tanks by condition and location. Plan what needs to be done for all tanks to be “integrity tested”. Plan what needs to be done for all tanks to be “integrity tested”. Schedule the “integrity Test”. Schedule the “integrity Test”.

28. Test Techniques Ultrasonic Thickness Testing (UTT) Ultrasonic Thickness Testing (UTT) Magnetic Flux Leakage (MFL) Floorscan Magnetic Flux Leakage (MFL) Floorscan Ultrasonic (UT) Corrosion Scanning (A- scan) Ultrasonic (UT) Corrosion Scanning (A- scan) Magnetic Particle Testing (MT) Magnetic Particle Testing (MT) Visual Examination (VT) Visual Examination (VT)

29. Ultrasonic Thickness Test

30. MFL Floorscan

35. Ultrasonic Corrosion Scanning

39. Visual Inspection

42. Holes from Soil Side Corrosion

43. Weeps

44. Conclusion Integrity Testing is accomplished by collecting the important tank variables and then determining what industry inspection standards make sense and then apply them. 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. Your P.E. must approve them into the plan.

45. Just remember, there are more painful things in life!