Iowa SPCC Tank Pres-Kupitz

8/6/2019 Iowa SPCC Tank Pres-Kupitz

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Tank Consultants, Inc.Tank Consultants, Inc.

4333 West 21st Street4333 West 21st StreetTulsa, Oklahoma 74107Tulsa, Oklahoma 74107--34443444

918918--583583--3968 Telephone3968 Telephone918918--583583--3966 Fax3966 Fax

www.tankwww.tank--consultants.comconsultants.com


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SPCC Tank Integrity TestingSPCC Tank Integrity Testing

Presented By: Kevin KupitzPresented By: Kevin Kupitz


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Whohas to test their tanks?Whohas to test their tanks?

If you have a facility withIf you have a facility withan aggregate oil storagean aggregate oil storagecapacity of 1320 gallonscapacity of 1320 gallons

you must inspect allyou must inspect allcontainers 55 gallons andcontainers 55 gallons andabove.above.

Applies toApplies toowners/operators thatowners/operators that

use oil. This woulduse oil. This wouldinclude storage capacityinclude storage capacityofoperating equipment.ofoperating equipment.


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What type of facilities does thisWhat type of facilities does this

include?include? SPCC States:SPCC States: oil of any kind or in any form, including but notoil of any kind or in any form, including but not

limited to: fats, oils, or greases of animal, fishlimited to: fats, oils, or greases of animal, fishor marine mammal origin; vegetable oils,or marine mammal origin; vegetable oils,including oils from seeds, nuts, fruits, or kernels;including oils from seeds, nuts, fruits, or kernels;and other oils and greases, including petroleum,and other oils and greases, including petroleum,

fuel oil, sludge, synthetic oils, mineral oils, oilfuel oil, sludge, synthetic oils, mineral oils, oilrefuse, or oil mixed with waste other thanrefuse, or oil mixed with waste other thandredged oildredged oil


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Facilities such as:Facilities such as:

MarinasMarinas General processingGeneral processing

RefineriesRefineries PipelinesPipelines TerminalsTerminals

Chemical plantsChemical plants Many other facilitiesMany other facilities


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SPCC plan reviewSPCC plan review

The original SPCC regulation was effectiveThe original SPCC regulation was effectivebeginning January 10, 1974beginning January 10, 1974


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RevisionsRevisions

The new revision requiresThe new revision requiresowner/operators to testowner/operators to testabove ground containersabove ground containersfor integrity on a periodicfor integrity on a periodicbasis.basis.

Most facilities shouldMost facilities shouldhave a plan already thathave a plan already that

only requires revising.only requires revising.


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Schedule for the new planSchedule for the new plan

Musthave your SPCC plan amended byMusthave your SPCC plan amended byAugust 17, 2004.August 17, 2004.

Must implement your plan by February 18,Must implement your plan by February 18,2005.2005.


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Why should I inspect my tanks?Why should I inspect my tanks?


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Why should I inspect my tanks?Why should I inspect my tanks?

To protectourTo protectourenvironment.environment.

EPA will audit facilitiesEPA will audit facilitiesas necessary.as necessary.

ND just fined 17ND just fined 17companies for overcompanies for over

$400,000.00.$400,000.00.

Oxychem penalty ofOxychem penalty of$137,500.00$137,500.00


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IssuesIssues

Incomplete plan.Incomplete plan. Failure to inspect tanks, valves, piping andFailure to inspect tanks, valves, piping and

appurtenances.appurtenances.

Failure to conduct integrity testingFailure to conduct integrity testing Lack of secondary containment for tanks.Lack of secondary containment for tanks. Inadequate secondary containment.Inadequate secondary containment.


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What does an O/O have to do toWhat does an O/O have to do to

comply?comply? SPCC does not refer toor mandate the use ofSPCC does not refer toor mandate the use of

any industry standard as related to tankany industry standard as related to tank

inspection. Although it states:inspection. Although it states: Consider the use of all relevant measures,Consider the use of all relevant measures,

including the use ofincluding the use of industry standardsindustry standards, as a way, as a wayto implement those measures.to implement those measures.

The decision in every case as to theThe decision in every case as to theapplicability of any standardapplicability of any standard will be one for thewill be one for theP.E.P.E.


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What industry standards do weWhat industry standards do we

need to consider?need to consider? APIAPI--653653

Written by tank builders, owners/operators and repairWritten by tank builders, owners/operators and repair

companiescompanies For self regulation rather than government regulationFor self regulation rather than government regulation

STI SP001STI SP001--03 was written by03 was written by

Tank buildersTank builders At the requestof the EPAAt the requestof the EPA


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APIAPI--653 applies to:653 applies to:

APIAPI--650 Welded Steel650 Welded SteelTanks for Oil StorageTanks for Oil Storage

APIAPI--12C, the predecess

or12C, t

he predecess

orto APIto API--650650

Any unknown standardAny unknown standard APIAPI--653 Certified653 Certified

InspectorInspector


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STI SP001STI SP001--03 applies to:03 applies to:

Tanks SHOP built to anyTanks SHOP built to anynationally recognizednationally recognizedstandardstandard

ULUL--142, 2085 and 2244142, 2085 and 2244

APIAPI--650 Appendix J650 Appendix J

APIAPI--12F12F

SwRI 97SwRI 97--04, 9304, 93--0101


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What tests do we have to do toWhat tests do we have to do to

comply?comply? Perform periodicPerform periodic Integrity Tests.Integrity Tests. Evaluate field constructed containers forEvaluate field constructed containers for

Brittle Fracture during repairs, alterationsBrittle Fracture during repairs, alterationsor change in service.or change in service.

Record keeping.Record keeping.


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What constitutes an Integrity Test?What constitutes an Integrity Test?

SPCC states:SPCC states:You must combine visual inspection withYou must combine visual inspection with

another testing technique such asanother testing technique such ashydrostatic testing, RT, UT, AE or anotherhydrostatic testing, RT, UT, AE or anothersystemofnonsystemofnon--destructive shell testing.destructive shell testing.

Test each above ground container forTest each above ground container forintegrity on a regular schedule, andintegrity on a regular schedule, andwhenever you make material repairs.whenever you make material repairs.


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What does this mean?What does this mean?

The actual inspection can be inThe actual inspection can be inaccordance with STI SP001accordance with STI SP001--03 or API03 or API--653653

or a combination of both.or a combination of both. Either way, the P.E. must sign offon theEither way, the P.E. must sign offon the

inspection technique.inspection technique.


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The tank inspection will beThe tank inspection will be

determined by a few main variablesdetermined by a few main variables SPCC states:SPCC states:The frequency of and type of testingThe frequency of and type of testing

must take into account container size andmust take into account container size anddesign (such as floating roof, skiddesign (such as floating roof, skidmounted, elevated, or partially buried).mounted, elevated, or partially buried).


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Example tank inspection for FieldExample tank inspection for Field

Erected Vertical Tank on Grade.Erected Vertical Tank on Grade.


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Example tank inspection for FieldExample tank inspection for Field

Erected Vertical Tank on Grade.Erected Vertical Tank on Grade. Monthly visual check by operator.Monthly visual check by operator. 5 year external by a certified inspector by5 year external by a certified inspector byVT and UT methods while the tank is full.VT and UT methods while the tank is full.

10 year internal inspection incorporating10 year internal inspection incorporatingVT, UT and/or MFL. Check tank bottom.VT, UT and/or MFL. Check tank bottom.

As an option, the tank could be liftedAs an option, the tank could be liftedexposing all sides of the tank.exposing all sides of the tank.


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Vertical tank on Grade with LeakVertical tank on Grade with Leak

Detection.Detection. Monthly visual check by the operator.Monthly visual check by the operator. 5 year external inspection by a certified5 year external inspection by a certified

inspector with tank full of product.inspector with tank full of product.

Internal inspection only when leaks areInternal inspection only when leaks arefound or the integrity is questioned by thefound or the integrity is questioned by the

certified inspector.certified inspector.


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Horizontal Tank with all SidesHorizontal Tank with all Sides

Exposed.Exposed.


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Horizontal Tank with all SidesHorizontal Tank with all Sides

Exposed.Exposed. Monthly visual check by operator.Monthly visual check by operator. Perform a 5 year external inspection withPerform a 5 year external inspection with

the tank full of product.the tank full of product. Perform thorough Ultrasonic (UT)Perform thorough Ultrasonic (UT)

evaluation on the lower 60 degrees of theevaluation on the lower 60 degrees of thetank.tank.

Perform UT scrubs on the heads of thePerform UT scrubs on the heads of thetank.tank.


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O/O with many tanksO/O with many tanks


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O/O with many tanksO/O with many tanks

Perform an Inventory/walk throughPerform an Inventory/walk throughinspection.inspection.

Prioritize tanks by condition and location.Prioritize tanks by condition and location. Plan what needs to be done for all tanksPlan what needs to be done for all tanks

to be integrity tested.to be integrity tested.

Schedule the integrity Test.Schedule the integrity Test.


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Test TechniquesTest Techniques

Ultrasonic Thickness Testing (UTT)Ultrasonic Thickness Testing (UTT) Magnetic Flux Leakage (MFL)FloorscanMagnetic Flux Leakage (MFL)Floorscan Ultrasonic (UT) Corrosion Scanning (AUltrasonic (UT) Corrosion Scanning (A--

scan)scan)

Magnetic Particle Testing (MT)Magnetic Particle Testing (MT)

Visual Examination (VT)Visual Examination (VT)


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Ultrasonic Thickness TestUltrasonic Thickness Test


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MFL FloorscanMFL Floorscan


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Ultrasonic Corrosion ScanningUltrasonic Corrosion Scanning


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Visual InspectionVisual Inspection


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Holes from Soil Side CorrosionHoles from Soil Side Corrosion


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WeepsWeeps


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ConclusionConclusion

Integrity Testing is accomplished byIntegrity Testing is accomplished bycollecting the important tank variables andcollecting the important tank variables and

then determining what industry inspectionthen determining what industry inspectionstandards make sense and then applystandards make sense and then applythem.them.

Your P.E. must approve them into theYour P.E. must approve them into theplan.plan.


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Just remember, there are moreJust remember, there are more

painful things in life!painful t

hings in life!

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Iowa SPCC Tank Pres-Kupitz