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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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