Is this still an Interior Lining?

Transcription

1 Is this still an Interior Lining? Heather Peters Missouri Department of Natural Resources

2 New Federal Language Installed in accordance with Inspected on 10/5 year interval If it is no longer performing in accordance with original design specifications and cannot be repaired in accordance with a code of practice developed by a nationally recognized association or independent testing laboratory, then the lined tank must be permanently closed

3 But my lining isn t for upgrades! Do you require inspection/ maintenance for other linings? Compatibility? Repair? Secondary Containment? Do those regulations require I & M?

4

5 Interior Lining- Standards American Petroleum Institute (API) RP1631 National Leak Prevention Asso (NLPA) 631 American Society for Testing and Materials (ASTM) G158? Purpose is for cathodic protection, not lining Underwriters Laboratory (UL)1856? Construction NOT Inspection

6 API 1631 (Periodic Inspections) Qualified person Thickness/ Hardness checked Holiday detector for air pockets, leaks, pinholes Steel tank integrity test required (must have at least 75% original steel thickness)

7 API 1631 (Periodic Inspections) Peeling Blistering Wrinkled surface Defects repaired to manufacturer specs

8

9 NLPA 631 B Lining Inspections Certify employees are knowledgeable Special inspector or qualified person Lining shall be tested: Signs of peeling, blistering, surface wrinkling Thickness/ Hardness/ Holiday testing Steel Integrity testing requirements (must have at least 75%/85% original steel thickness)

10

11 API 1631 and NFPA 631 Both allow linings to be repaired Both require passing (75%) integrity assessment of the steel tank Both have detailed breakdown of the number and location of steel tank measurements Does not allow mean-time-to-corrosion in lieu of steel shell evaluation

12

13

14 Video Inspections???? Ken Wilcox Associates Recommended Practice for Inspecting Buried Lined Steel Tanks Using a Video Camera Defines certified/qualified persons Signs of separation, delamination, blistering, peeling, holidays Thickness/ Hardness test (minimum 5 at each opening) Inspection only

15 Certifications? Confined Entry NACE International Coatings Inspector International Code Council (ICC) UST Installation/Retrofitting Society for Protective Coatings (SSPC) State specific?

16 UL1856- The New Retrofit Standard 1. Lining: single-walled 2. Upgrade: double-walled Co-structural : requires original host tank integrity 3. Self-structural: double-walled Does NOT require original host tank integrity Does NOT require steel tank to pass integrity test

17 Lining (UL1856) Single-walled Lining flush against steel Steel assessment in standards

18 Upgrade, double-walled Two walls of the lining First layer against steel Interstitial space Steel integrity required

19 Self-structural Two lining layers First layer against steel Interstitial space Steel integrity NOT required

20 Inspections Video/ Manned Inspection Every 5 years Assesses steel Assesses lining condition Failure only detected at inspection (once in 5 years)? Interstitial Monitoring Continuous (NWGLDE def) Checks every day for 5 years Interstitial check catch interior wall failure from portion that contains fuel Exterior fail may be seen Does not assess condition or approaching problems Detects failure immediately

21 Inspections and Monitoring Single-wall Lining Video inspection Entry inspection 5 year test (only option) Steel integrity Double-wall Upgrade Video inspection (inside layer) Entry inspection (inside layer) 5 year test Interstitial testing? Steel Integrity Can I even inspect it? Self-structural Video inspection (inside layer) Entry inspection (inside layer) 5 year test Interstitial testing? Steel Integrity Can I inspect it? If steel doesn t matter, can I exclude it?

22 Can I even inspection it? Lining: Yes, traditional inspection Double-walled co-structural: Video? Interstitial? If you allow G158 for steel assessment? NOT INTENDED PURPOSE Self-structural: Inner layer only (if waive steel assessment)? If you allow interstitial? Video?

23 Steel Integrity Assessment Can I do it? Must I do it? Lining (single-walled) YES YES Double-walled lining NO?? YES Self-structural NO?? NO?? YES?

24 Is it eligible for repair? Lining: Steel passes Double-walled, co-structural: If you allow mean-time-to-corrosion? No repairs? Self-structural: Manufacturer repair only? No repairs? Is a re-lining a repair? If okay to patch, but prefer to re-line.

25 Patch? But not Re-line?

26 Rules, Installs, Inspections Regulation: Inspect to industry standard Inspection Standard: Can repair IF steel passes UL1856 Installation Standard: Steel is irrelevant for Self-Structural What do I do?

27 Your Regs - Your SPA Opening Regulations Understand the standards What works for your state? Can you prove it is equitable? Talk to EPA about your SPA!

28 Questions- Now or End of the Presentations