Above Ground Storage Tank

Design, Inspection, and Compliance Management

By Gregory Coppola, P.E. Kinder Morgan Energy Partners, L.P.

Introduction
Kinder Morgan Overview
Midstream Energy Company 900+ Storage Tanks in Pacific Region Critical Infrastructure for Fuel Distribution

Completed New Tanks El Paso, TX

Organization of the Presentation

Objective of the Presentation API Recommended Practice Tank Construction and Tank Components Out-of-Service Inspections Regulatory Framework
SPCC Rule APSA DOT Regulations Air Regulations Federal and Local

Objective of the Presentation

Provide CUPA members with an overview of petroleum storage tanks. Provide an introduction to applicable regulations. Assist with CUPA regulation under Assembly Bill 1130, The Aboveground Petroleum Storage Act.

Aboveground Petroleum Storage Act (APSA), Assembly Bill 1130

Effective January 1, 2008
Transfers the responsibility for the implementation, enforcement and administration of the Aboveground Petroleum ACT (APSA) from the State Water Resources Control Board (SWRCB) to the CUPAs. California Health and Safety Code Chapter 6.67, Sections 25270 25270.13 are also known as the APSA. APSA will be discussed in more detail later in the presentation.

API Recommended Practices

API Recommended Practices API 650

API 650 Design Standard for welded steel tanks for oil and fuel storage. Typically used for large field fabricated storage tanks operating at low pressures or atmospheric pressures. The standard covers materials of construction, design, fabrication/erection, construction inspection, and welding procedures.

API 650 Welded Tanks for Oil Storage

Scope Reference Definitions Materials Design Fabrication Erection Methods of Inspection Welding Procedures Marking

Tank Schematics
The following schematics show the various appurtenances for:
Cone Roof Tanks Internal Floating Roof (IFR) Tank with Top Foam Injection and Vapor Recovery Cable Suspended IFR External Floating Roof (EFR) EFR with Dome

Cone Roof Tank

IFR Tank w/Top Foam and Vapor Recovery

Cable Suspended Internal Floating Roof

External Floating Roof Tank

EFR Tank with Aluminum Dome

Tank Foundations
Foundation Types
Earth Foundations Gravel/Asphalt Surface Ring Walls Slab Piles with Ring or Slab Caps

Tank Foundations (Cont)

Design Concepts
Vertical Loading
Liquid pressures Shell and roof loads

Overturning
Wind Seismic

Foundation Settlement

Liner Installation

Foundation Rebar

Concrete Tank Foundation

Tank Bottoms
Constructed of overlapping steel plates. Plates joined by manual or automatic arc welding techniques. Tank bottom to shell welds undergo the most stress and are considered critical welds.

Tank Bottom In Progress

View of Tank Bottom Beneath IFR Includes Center Column, Roof Legs, and Reinforcing Pads

Tank Double Bottoms

Typical components (starting from below)
Lower tank bottom HDPE liner Sand or concrete with drainage system Upper tank bottom

Shell Design
Tank shells are constructed from courses of steel plates. The designer will calculate a steel thickness for each course. The bottom courses are thicker steel due to hydrostatic pressure. Shell design criteria include hydrostatics and wind buckling. Thickness includes corrosion allowance.

Construction of First Course Crane Inside

Construction of First Course

Hanging Plate for 4th Shell Course

Nozzles and Penetrations

Openings in the shell result in higher stress. Repads or thickened inserts may be required. Stress relieving may be required.

Manway with Davit Arm

Fixed Roof Types

Self-supported
Cones Domes and Umbrellas with stiffeners

Supported Cone Roofs

Columns are inside tank

Aluminum Geodesic Domes

Roof Construction Bull Wheel and Center Column

Roof Rafter Construction

Lifting Cone Roof

Center Column Support

Supported Roof, Partially Completed

Aluminum Dome, Lifting on to EFR Tank

Frangible Roof Joints

Roof to shell junction designed to fail first in an emergency. Future piping and maintenance must not interfere with the functioning of the frangible roof joint.

Fixed Roof 24 Mushroom Circulation Vent, Sample Vent and Skid-Proof Surface Coating

Floating Roofs, Objectives

Reduces air emissions Prevents product loss Meets regulatory requirements Improves fire safety

Floating Roofs
Material of Construction: Steel or Aluminum Roof Types
Floating pan Bulkhead Internal pontoon Double deck Honeycomb or Foam Core Cable suspended Aluminum

IFR Pontoon Construction

Floating Roof Support Leg and Sleeve (High Leg Position)

Reinforcing Pad for Roof Leg

Floating Roof Seals

Primary Seals
Liquid mounted foam logs Liquid mounted shoe seals Vapor mounted foam logs Vapor Mounted wipers

Secondary Seals
Elastomeric wipers Metallic wipers

Mechanical Primary Shoe Seal in IFR

Compression Plate Secondary Seal with Wiper Tip on EFR Tank

Other Tank Appurtenances

Spiral stairway Ladders Level gauges Pressure vacuum vents Shell and roof manways Inlet diffusers Drain sumps Roof drain hoses

Spiral Stairway Leading up the Tank Exterior

Internal Ladders with 8-inch Slotted Gauge Pole

Level Gauging Systems

Mechanical level gauging systems are frequently used. There are multiple alarm levels. Radar gauges can be mounted at the fixed roof or in a gauge well. The gauging system often ties into the overall facility SCADA system. A redundant alarm is recommended by API.

Level Gauging System Mounted on Tank Exterior

Sample Hatch

Top View of IFR Two 12 Pressure Vacuum Vents and Center Column

Drip Tray for Center Column with Hold Down Chains

Ladder Well Drip Tray and Chained Slide Plate

Tank Bottom Sump Newly Painted

Ladder, Slotted Gauge Pole, and Sump

Slotted Inlet Diffuser

Slotted pipe

Inlet Diffuser -- Hole Type

Suction Line Trough

Water Draw Piping

Coiled Roof Drain Hose Beneath Internal Floating Roof

Reinstalling a Door Sheet at the Conclusion of the Project

Fire Systems
Refer to NFPA 11 Standard for Low-, Medium-, and High-Expansion Foam. The Standard contains design criteria for hydrocarbon storage tanks. The criteria include:
Application rate Discharge time Minimum number of outlets

Fire Systems (Cont)

Fixed roof tanks may be designed with subsurface injections. Floating roof tanks will be designed with over-the-top injection. Foam dams are used to focus on fighting seal area fires. Other fire systems are designed for Full Surface Fires.

Foam Fire Systems

Foam Chamber Installed in Tank Shell

Tank Cathodic Protection

Galvanic Corrosion
Can occur on the underside of a tank bottom causing oxidation, general corrosion, and pitting. Galvanic cell requires:
Anode active metal at the tank bottom. Cathode less active metal in the vicinity of the tank. Electrical path tank bottom and soil. Electrolyte.

Tank Cathodic Protection (Cont)

Impressed Current Systems
Includes a DC current source created by a rectifier and a buried impressed current anode. Creates a current to counteract the galvanic cell and forces current to the tank bottom to prevent oxidation (loss of electrons).

Sacrificial Anode
The anode losses electrons rather than the tank.

Impressed Current Corrosion Protection

API Recommended Practices API 653

API 653 Tank Inspection, Repair, Alteration and Reconstruction. Tanks are inspected to determine their suitability for service. The standard includes recommendations for tank inspection interval. This standard governs out of service inspection and repair work.

API 653
Tank Inspection, Repair, Alteration and Reconstruction

Scope Reference Definitions Suitability for Service Brittle Fracture Inspection Materials Design Considerations

Tank Repair and Alterations Dismantling/Reconstr uction Welding Examination Testing Marking

Other API Methods Relevant to Tanks

API 651 Cathodic Protection for Storage Tanks. API 652 Linings for Storage Tanks. Standard for Internal Coating. API 2000 Venting for Atmospheric and Low Pressure Tanks. API 2350 Overfill Protection for Storage Tanks.

API Recommended Inspection Schedule

Routine In-Service Visual Inspection
Frequency not to exceed one month. Can be performed by Owner/Operator personnel.

External In-Service Inspection

Visual inspection of the tank exterior . By Authorized Inspector (API 653 Certified). Frequency not to exceed 5 years, but may be more frequent based on corrosion calculation.

API Recommended Inspection Schedule

Ultrasonic Inspection
Ultrasonic measurement of tank shell. Inspections at 15 year intervals or possibly more frequent based on shell corrosion calculation. Initial inspection in 5 years to establish a corrosion rate. Corrosion rate may be estimated from tanks in similar service.

API Recommended Inspection Schedule (Cont)

Internal Inspection
Inspections at 20 year intervals or possibly more frequent based on tank bottom corrosion calculation. Initial inspection in 10 years to establish a corrosion rate. Corrosion rate may be estimated from tanks in similar service.

Tank Maintenance Projects Typical Tasks

Empty tank. Isolate. Clean and degas. Inspection blast of floor coating. API 653 inspection. Issue preliminary inspection report and develop list of maintenance/repair items. Perform tank maintenance and repair work.

Tank Maintenance Projects Typical Tasks (Cont)

Tank strapping Final blast Tank coating Final inspection Return tank to service Exterior painting or concrete/asphalt work (optional) Final construction documentation

Safe Work Practices

Safety is Everyones Job Learn to Recognize Safe Work Practices

Safe Work Permitting Procedure

Heavy Tools are Lifted by Rope Tag Line not Hand Carried

Confined Space Vapor Monitoring

Radio Communication

Leg Setting
The tank contractor will set the IFR legs from high position to low position to land the roof. This requires a confined space entry from the manway on the fixed roof.

Use Body Harness and Tripod for Confined Space Entry

Tripods Must Have Leg Chains for Stability

Pulley Must be Mounted and Secure

Body Harness Must Be Properly Attached

Lock Out / Tag Out

Lock out, tag out procedures are followed for piping and electrical. Contractors verify that all valves have been closed and locked out. Ensure that the terminal piping has been totally isolated (review terminal piping drawings).

Plan Lockout/Tagout

Gauge the Tank to Check that it is Empty

Close, Lock, and Tag Valves to Isolate

Electrical Lockout/Tagout

Tank Valve Lockout

Document the Valve Positions

Tank Isolation
For all lines, a valve is removed and blinded to create an air gap. Metal drip pans and vacuum truck are required when isolating the tank. Bonding cables are required when removing valves. 150 lb. blind flanges and new gaskets are required. After blinding has been completed, the piping is visually inspected to ensure tightness.

Inspecting Empty Vacuum Truck Prior to Use

Bonding Cables and Metal Drip Pan

Valve removal including bonding cables, respirators, gloves, fire extinguisher, metal drip pans and vacuum truck hose.

Isolated Tank Valve with Air Gap

Isolated Buried Line with Barricades

Tank Degassing
Tank degassing is performed, when required, based on product type and location in accordance with EPA, State, or local air regulations. Portable Thermal Oxidizers are most frequently used to handle the combustion throughput. IC engines or activated carbon systems can be used. The units need to have the appropriate air permit and operate in accordance with the permits.

Portable Thermal Oxidizer and Generator

Degassing Unit Placed Outside of Tank Berm

IC Engine Degassing Unit

Temperature and Flow Monitoring is Typically Required by the Air Permit

Once the Manway is Removed Plastic Sheeting is Place over it Immediately

The Vapor Hose Penetrates the Plastic Sheeting

Tank Cleaning
Proper placement of equipment to separate vapors from ignition sources. Proper PPE (hard hats, rubber boots, gloves, suits, full body harness, etc.). Enter with supplied fresh air. Monitor vapors inside the manway away from inlet. OSHA allows tank entry below 10% LEL for fresh air work; however, the goal is to be significantly lower.

Hose Extends from Vacuum Truck to Tank Manway

Vacuum Truck Exhaust Connected to Carbon Canister

Manway Setup Plastic Sheet, Fire Extinguisher, Confined Space Permits

Intrinsically Safe Fan Mounted on Opposite Manway from Entrance

PPE for Tank Entry

Interior Appurtenances Removed to Drain Product

Center Column Mouse Hole Drained of Product

Marine Chemist Certifies the Tank as Gas Free

The gas free certificate is posted over the manway. It may have certain restrictions to be aware of.

Confined Space Access is Secured when the Contractor Leaves the Site

Cribbing Blocks Installed to Support Roof

Anti-Rotational Roof Support

API 653 Tank Inspection Techniques

Magnetic Flux Exclusion (MFE) Ultrasonic Testing (UT) Vacuum Box Testing Dye Penetrant Testing Bottom Settlement Survey

Calibration of Magnetic Flux Exclusion (MFE) Bottom Scanner

Large MFE/UT Floor Scanner

Scans within 2 of Lap Weld Seams

Marking Corrosion Indications Circles Topside Corrosion Square Bottomside Corrosion

Calibration of Smaller Hand Scanner

Smaller Scanner in Congested Area

Hand Scanner used at Corner Weld

Remaining Floor Thickness is Marked in Area of Soil Side Corrosion

Automated Ultrasonic Thickness Measurement used to Prove Up locations marked during MFE Scan

Vacuum Box Testing of Corner Weld

Vacuum Box Testing of Floor Plate Weld Seam

Fluorescent Dye Penetrant Applied to Corner Weld

Using Black Light to Find Defects Detected with Fluorescent Dye

Bottom Settlement Survey

Ultrasonic Testing of Tank Shell

Ultrasonic Testing of Shell Reinforcement Pad and Nozzle

Ultrasonic Testing of Internal Floating Roof

Tank Repairs

Tank Repairs
Floor Patches and Plate Replacements Shell Repairs IFR Repairs Nozzles Seal Replacement Tank Valve Repairs Calibration and Repair of Gauging System Follow-up Testing

Testing of Vapors Beneath Tank Floor Through Small Hole Drilled in the Floor

Bottom Repair at Critical Zone

Testing New Patch With Soapy Water

Dye Penetrant Testing of Shell Nozzle

Roof Drain Hose Inspection

Replacing Seal Apron Fabric

Fluorescent Testing Beneath IFR

Inspecting the Penetrant Test Above the Roof to Search for Leaks

Pressure Testing Pontoons Following Repairs

Tank Interior Coating

SPCC Compliance

Purpose of SPCC Rule

Requirements help prevent oil discharges from reaching navigable waters or adjoining shorelines. Certain facilities are required to develop SPCC Plans that describe equipment, workforce, procedures, and training to prevent, control, and provide adequate countermeasures to a discharge of oil.
Must comply with the rule requirements. Must also implement the written Plan.

What does the SPCC Rule Require?

Requires facilities to develop and implement a site-specific SPCC Plan to address:
Containment and procedures to prevent oil discharge (operating procedures, inspections & tank testing, training, etc.) Control measures to keep an oil discharge from entering navigable waters (containment, drainage valves Countermeasures to contain, clean up, and mitigate any oil discharge that affects navigable waters (spill response measures)

Performance-based rule designed to implement the Congressional policy of no oil discharges to waters of the United States

Aboveground Petroleum Storage Tank Act (APSA)

What is an Aboveground Petroleum Storage Tank?

55 gallons or more. Located substantially above ground. Tanks are either UST or AST, but not regulated as both. The volume for mixtures is based on the total tank capacity not the volume of petroleum in the mixture.

APSA Exemptions
Two broad exemptions:
Exempt Tanks (HSC 25270.2(a)(1 6))
Some exemption conditions (and compliance with those conditions) should be verified

Exempt Facilities (HSC 25270.4.5(b))

Exempt only from APSA requirement to prepare and implement an SPCC Plan

Tanks Exempted Under APSA

Boilers & pressure vessels Waste & used oil tanks
Located at DTSC permitted hazardous waste TSD facilities (and listed on the permit), or specifically listed on a facilitys PBR Tiered Permit

Crude oil production tanks Most oil-filled electrical equipment CUPA regulated USTs Transportation-related tank facility

APSA (and SPCC Rule) Exempt Tanks

Transportation-related facilities are not regulated under federal SPCC rules or APSA Facilities are divided into three categories:
Transportation-related facilities (exclusively regulated by DOT / DOI) Non-transportation-related facilities (not exclusively regulated by DOT / DOI) Complexes (regulated by both)

Jurisdiction was established through a series of Executive Orders (EOs) and Memoranda of Understanding (MOUs)

EOs and MOUs

Executive Order 11548 delegated responsibilities for regulating oil discharges (later superseded by E.O. 11735 and 12777).
EPA: Non-transportation-related facilities DOT: Transportation-related facilities

EPA-DOT MOU (1971) defines transportation- and non-transportation-related. DOT-DOI-EPA MOU (1994) establishes responsibilities for offshore facilities, including pipelines.

Non-Transportation-Related Facilities
(CUPA Jurisdiction under APSA)
Oil refining and storage facilities Industrial, commercial, non-exempt agricultural, and public facilities that use and store oil Waste treatment facilities Loading areas and racks, transfer hoses, loading arms, and other equipment used to transfer oil in bulk to or from highway vehicles or railroad cars Highway vehicles, railroad cars, and pipelines used to transport oil within confines of nontransportation-related facility

Transportation-Related Facilities
(DOT Jurisdiction)
Onshore and offshore terminal facilities, including transfer hoses, loading arms, and other equipment used to transfer oil in bulk to or from a vessel; including storage tanks and appurtenances for the reception of oily ballast water or tank washings from vessels Transfer hoses, loading arms, and other equipment appurtenant to a non-transportation-related facility used to transfer oil in bulk to or from a vessel Interstate and intrastate onshore and offshore pipeline systems Highway vehicles and railroad cars that are used for the transport of oil

Complexes
(CUPA and DOT Jurisdiction)

A facility with both transportation-related and non-transportation-related activities is a complex facility and is subject to the dual jurisdiction of the CUPA under APSA and DOT.

Underground Piping Associated with Aboveground Tanks

APSA does regulate buried piping. The federal SPCC regulations contain requirements for buried piping at a regulated facility and APSA requires the implementation of the SPCC Plan for ASTs.

APSA Regulated Piping

Must be connected to the tank. APSA applies to:
Piping in the containment area. Piping up to the first valve or flange outside the containment area. If there is no containment, piping connected to the first flange or valve.

Federal SPCC rules for the facility may be broader and include piping not integrally related to the storage tank.

APSA (SPCC) Compliance Verification

Written Plan review
All rule-required content (and format) Facility-specific descriptions, procedures, etc.
Can be narrative, generic

Inspect for compliance with the detailed rule requirements

Whether adequately described in the Plan or not

Verifying the written Plan is consistent with field conditions Verifying that the facility is implementing the Plan as written

DOT Compliance

Applicable DOT Regulations

Applicable to breakout tanks and pressure relief tanks at petroleum transportation facilities. DOT views the tanks as part of the pipeline. CFR Title 49 Transportation.
Part 195 Transportation of Hazardous Liquids by Pipeline.

Applicable Sections of DOT Regulations for Tanks

195.132 -- Design and Construction of Above Ground Breakout Tanks. 195.307 -- Pressure Testing Above Ground Breakout Tanks (hydrostatic testing). 195.432 -- Inspection of In-Service Breakout Tanks. Subpart G -- Operator Qualification (OQ) Training Program.

DOT Applicable Regulations

Part 195.432 Each operator must inspect the physical integrity of in-service atmospheric and low-pressure steel aboveground breakout tanks according to API Standard 653 (incorporated by reference, see 195.3). However, if structural conditions prevent access to the tank bottom, the bottom integrity may be assessed according to a plan included in the operations and maintenance manual under 195.402(c)(3).

Air Regulations

Air Compliance
Air Compliance rules are confusing, complex, and sometimes conflicting. This presentation will just provide a broad outline of rules. Rule applicability determination depends on:
the year the tank was built, tank volume, vapor pressure of liquid.

Clean Air Act (CAA) Regulations

Ozone Precursors (VOCs) Title 1, the source is the individual tank.
NSPS Rule, 40CFR Part 60
Subpart K Effective 6/11/73 Subpart Ka Effective 5/18/78 Subpart Kb Effective 7/23/84

Control Technology Guidelines (CTG), Reasonably Available Control Technology (RACT) rules

Clean Air Act Regulations (Cont)

Control Technology Guidelines (CTG), Reasonably Available Control Technology (RACT) rules.
Applies to existing source in non-attainment areas. 1977 Fixed Roof Tank. 1978 EFR Tank. 1994 ACT for VOL Storage.

Clean Air Act Regulations (Cont)

Air Toxics Hazardous Air Pollutants (HAPs Rule), Title III
NESHAPS (40 CFR Part 61).
These rules are specific to individual chemical in individual tanks. Subpart Y is for Benzene.

NESHAPS (40 CFR 63)

Rule applies to all HAPs and the source is the entire facility.

Clean Air Act Regulations (Cont)

NESHAPS (40 CFR 63) Continued
SOCMI HON Gasoline Distribution Petroleum Refineries Oil and Gas Production (a.k.a. E&P MACT) Organic Liquids Distribution (a.k.a. Old MACT)