Integrity Testing of

Aboveground Storage
Tanks
2012 Southern Section AWMA
Annual Meeting and Conference

Andrew Covington, P.E.

 Presentation Outline
• Introduction
• About Eco-Systems, Inc.
• What Is Integrity Testing?
• Why Should I Have My Storage Tanks Inspected?
• SPCC Regulations
• Baseline Conditions
• Regulations/Industry Standards
• STI SP001
• Hybrid Inspection Program
• Environmental Equivalence
• Other Considerations
• Regulatory Deadline
• Eco-Systems, Inc. Services
• Questions
 Introduction
Andrew Covington, P.E.
◦ Professional Engineer
◦ MS, AL, GA, LA, TX
◦ Environmental/Petroleum Engineer
◦ STI Certified Inspector
◦ 30 Years of relevant Experience
◦ Expertise
 Permitting & Compliance
 Air Quality
 SPCCs & SWPPPs
 About Eco-Systems, Inc.
FullService Environmental Consulting
Firm
Service Areas:
◦ Permitting & Compliance,
◦ Natural Resources,
◦ Remediation,
◦ Planning, and
◦ Engineering & Construction
 What Is An SPCC?
Federal regulation that requires a spill
prevention control and countermeasure (SPCC)
plan be in place.
Designed to detect and prevent oil leaks, spills,
or other potential integrity or structural issues
before they can result in a discharge of oil to
navigable waters of the U.S.
What Is Integrity Testing?
A test performed to determine the useful life of
a Storage Tank.
Visual Inspection is an accepted integrity testing
technique.
Non-destructive type shell testing (Hydrostatic
Testing, Radiographic Testing, Ultrasonic
Testing, Acoustic Emissions Testing, etc.).
 Why Should I Have My
Storage Tanks Inspected?
Workplace Safety Considerations
Protection of the Environment
Industry Standards
Good Engineering Practices
Regulatory Requirements
Purpose of SPCC
and tank integrity
testing?
 SPCC Regulations
40 CFR Part 112.8 (C) 6
Test or inspect each aboveground container for
integrity on a regular schedule and whenever
you make material repairs.
You must determine, in accordance with
industry standards, what are the appropriate
qualifications for personnel performing tests
and inspections, the frequency, and type of
testing and inspections.
Take into account container size, configuration,
and design.
 SPCC Regulations
40 CFR Part 112.8 (C) 6
You must inspect the container's supports and
foundations.
You must inspect the outside of the container
frequently for signs of deterioration, discharges,
or accumulation of oil inside diked areas.
You must keep complete records.
 SPCC Regulations
Testing on a ‘regular schedule’ means testing
per industry standards or at a frequency
sufficient to prevent discharges. Whatever
schedule the P.E. selects must be documented in
the Plan.
 SPCC Regulations
P.E. may choose to develop an inspection and
testing program for the facility’s shop-built
tanks in accordance with
◦ STI SP001,
◦ API 653, or
◦ Hybrid Program
 Industry Standards
SteelTank Institutes (STI) SP001
American Petroleum Institute (API) 653
National Fire Protection Association Fire Code
(NFPA 30)
Local Fire Code(s)
API 575 Atmospheric and Low Pressure Tanks
API 570 Piping Inspection Code
 STI SP001
Standard For The Inspection Of Aboveground
Storage Tanks (Sept 2011, 5th Edition)
Section 1.2 states that SPOO1 standards are
minimum requirements.
Applies to:
◦ Aboveground Storage Tanks.
◦ Storing Stable, Flammable, & Combustible Liquids at
Atmospheric Pressure and having a Specific Gravity
less than 1.0.
◦ Operating Ambient Temperatures up to 200 Deg F.
 STI SP001
 Ata minimum, the following tank components shall be
inspected (as applicable):
◦ Primary tank
◦ Secondary tank
◦ Tank supports
◦ Tank anchors
◦ Tank foundation and external supports
◦ Tank gauges and alarms
◦ Insulation covering
◦ Tank appurtenances
◦ Normal vents
◦ Emergency vents
◦ Release prevention barriers
◦ Spill control systems
 STI SP001
Tank Categories:
◦ Category 1
 Secondary Containment
 Continuous Release Detection Method (CRDM)
 (Example - Elevated Tank where all sides of the tanks can
be inspected except at the supports)
◦ Category 2
 Secondary Containment
 No CRDM – (Example - Tank shell in contact with soil)
◦ Category 3
 No Secondary Containment
 No CRDM
STI SP001
STI SP001
 STI SP001
Inspection Of Field-Erected ASTS (Appendix B)
 STI SP001
Periodic AST Inspections
Conducted by Owner’s Inspector
The personnel performing these inspections
shall be knowledgeable of storage facility
operations, the type of AST and its associated
components, and characteristics of the liquid
stored. (4.1).
STI SP001 Formal External
and Internal Inspections
Conducted by Certified Tank Inspector (4.2)
A Certified Tank Inspector shall be certified by
one or more of the following:
◦ API Standard 653 Authorized Inspector Certification
with STI SP001 Adjunct Certification.
◦ STI Certified SP001 AST Tank System Inspector.
◦ Additional certifications as may be required by
individual states or other governing bodies.
 STI SP001
Suitabilityfor Continued Service (10.0)
Next formal internal inspection or the next
formal external inspection, as applicable, may
exceed the interval listed in STI SP001 (Table
5.5), if the corrosion rates allow and as
determined by P.E.
 STI SP001
Other Tank Damage (10.3)- An AST requires
evaluation by an experienced engineer or tank
manufacturer to determine if further action is
needed if tank subjected to damage caused by
the following conditions :
◦ Fire
◦ Natural disaster
◦ Excessive Settlement
◦ Overpressure
◦ Damage from Cracking
 STI SP001
Recordkeeping (11)
◦ Retain each AST Record for the life of the AST.
◦ Retain each Monthly Inspection Checklist for at least
36 months.
◦ Retain each Annual Inspection Checklist for at least 36
months.
◦ Retain each Portable Container Monthly Inspection
Checklist for at least 36 months.
◦ Retain all Certified Inspection Reports for the life of
the AST.
 Baseline Conditions
ASTs With Known Baseline Conditions
◦ Shell thickness and
◦ Corrosion rates

Only when the baseline is known, an inspection

and testing program can be established on a
regular schedule as per Industry Standards.
 Baseline Conditions
ASTs With Unknown Baseline Conditions
◦ For ASTs baseline conditions are not known,
◦ A regular integrity testing program cannot be
established.
◦ P.E. must describe an interim schedule in the SPCC
Plan.
Hybrid Inspection Program
The P.E. may use industry standards, along
with other good engineering principles, to
develop a customized inspection and testing
program for the facility.
Environmental Equivalence
◦ 40 CFR 112.7(a)(2) – Allows deviations from some
requirements when the owner provides equivalent
environmental protection by some other means of spill
prevention, control, or countermeasure.
Environmental Equivalence
Petroleum Marketers Association of America
(PMAA) SETTLEMENT LANGUAGE:
Well-designed shop-built containers with a
shell capacity of 30,000-gallons or less
Visual inspection plus elevation of a shop-
built container and makes all sides of the
container, including the bottom, visible during
inspection.
Environmental Equivalence
PMAA SETTLEMENT LANGUAGE:
 Visual inspection with placement of a barrier between
the container and the ground, designed and operated in
a way that ensures that any leaks are immediately
detected.

 P.E. should begin by consulting appropriate industry

standards, such as those listed in Steel Tank Institute
Standard SP001 and API Standard 653.
Environmental Equivalence
PMAA SETTLEMENT LANGUAGE:
P.E. may wish to consult industry standards such
as Underwriters Laboratory 142 or API Standard
650, Appendix J.

Where a facility is considering environmental

equivalence approach for containers resting on the
ground, or presents risks for corrosion, the facility
should first evaluate the condition of the container
in accordance with good engineering practices,
including seeking expert advice, where
appropriate.
 Other Considerations
NFPA 30
Local Ordinances
 Regulatory Deadline
Certainfacilities were required to comply
by November 10, 2011.
Eco-Systems, Inc. Services
SPCC Plan Review and Update
Integrity Testing Program Set Up
STI SP001 Certified Tank Inspections
Consulting
Tank You!!!
Questions???