2001ASTSFTI

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Shop-Fabricated Tank Inspection: 

Shop-Fabricated Tank Inspection Chris Bashor Minnesota Pollution Control Agency June, 2001

Shop-Fabricated Tank Inspection: 

Shop-Fabricated Tank Inspection History of States-EPA Workgroup Interest STI Standard SP001-00 Comparison with API 653 Relevance of SP001-00 to States and EPA Issues Conclusions

History of States-EPA Workgroup Interest: 

History of States-EPA Workgroup Interest EPA identifies SPCC need: no industry standard for inspection of small tanks Steel Tank Institute develops draft standard Workgroup reviews draft standard at May 2000 meeting and submits comments Final STI standard: September 2000

STI Standard SP001-00: 

STI Standard SP001-00 Steel Tank Institute Applicability Periodic inspections Certified inspections

Steel Tank Institute: 

Steel Tank Institute www.steeltank.com Contact: Dana Schmidt 847-438-8265 Paper copies available for $35 Electronic version was emailed to states

Applicability: 

Applicability Shop-fabricated ASTs (up to 50,000 gal) Built to national standard (e.g. UL142) Storage of “noncorrosive, stable, flammable, and combustible liquids having specific gravity not exceeding that of water” Includes foundation and vents, but not piping

Applicability (cont): 

Applicability (cont) Can be used for double-walled tanks Elevated or not, horizontal or vertical, manway or not MN believes standard is applicable for the most part to tanks of these types storing most other liquids, even if non-standard construction Corrosive liquids need special attention

Periodic Inspections: 

Periodic Inspections Qualifications: owner or any employee (no training) Monthly: water draw; DW interstitial space; pipe connections Quarterly: “walk-around” for damage, external coating, cleaning, repairs, vents

Periodic Inspections (cont): 

Periodic Inspections (cont) Annually: proper drainage, foundation Other: recordkeeping checklists, diagrams, maintenance info, references

Certified Inspections: 

Certified Inspections Qualifications: API 653 certified STI certified Frequency: every 10 years, or more often based on calculated minimum remaining wall thickness

Certified Inspections (cont.): 

Certified Inspections (cont.) Procedures: All visual per periodic checklists Pressure test for tightness Shell inspection

Certified Inspections (cont.): 

Certified Inspections (cont.) Shell inspection methods depend on whether tank is single or double-walled, elevated or not, has manway or not, has cathodic system or not Procedures include: Ultrasonic thickness testing (criteria given) Visual inspection (minimal criteria given) ASTM G 158 NACE RP-0285

Comparison with API 653: 

Comparison with API 653 In general, SP001-00 is much less rigorous No standards for repairs or alterations No provisions for upgrading non-UL142 to acceptable condition All in all, however, generally appropriate to level of risk involved

Relevance of SP001-00 to States and EPA: 

Relevance of SP001-00 to States and EPA Minnesota Other states EPA

Minnesota: 

Minnesota SF tanks at small facilities: Rules require equivalent of periodic but not certified Rule change would be needed for certified SF tanks at major facilities: Permits do not now require inspection of SF tanks Re-permitting will require SP001-00 starting 2001

Minnesota: 

Minnesota Enhancements to SP001-00 to be required: Walk-around inspection monthly Periodic records kept for three years, certified report kept for life of tank Records and reports must document repairs needed and made Repairs recommended must be made unless waived Certified report must include UT and other data

Minnesota: 

Minnesota So far, no facilities seem to be using SP001-00 Owners waiting for state/federal requirement? Some consultants now use API 653 for SF tanks Consultants who are API 653 certified will be in a position to offer lower cost SP001-00 certified inspections

Other States: 

Other States Wisconsin Working with STI to offer inspector certification Pennsylvania Has its own integrity inspection criteria Other states?

EPA: 

EPA Current SPCC requires “periodic integrity testing”, gives examples of visual and N-D shell thickness (UT) testing (112.7(e)(2)(vi)) SPCC revisions (when final) will be more specific about frequency and technique, and will specifically refer to SP001-00

Issues: 

Issues Standard has weaknesses Availability of qualified inspectors How to get the owner “into the program” How to get that first certified inspection

Conclusions: 

Conclusions On the whole, SP001-00 should prove valuable States and EPA can jointly have a positive influence on industry standards, e.g. STI, API (new RBI standard), Fertilizer Institute Would like to see more partnering with industry groups on AST standards, especially with API