Aboveground Storage Tank Inspection – A Tale of Four States

Updated: Aug 19, 2021

TechKnowServ Corporation (TKS) is strategically located to serve New York, New Jersey, Ohio Pennsylvania, and West Virginia owners and operators of aboveground storage tanks (AST) used to store chemical bulk and petroleum bulk products. In addition to our strategic location, we are proficient in the different jurisdictional requirements for each state. This article outlines some of the aboveground storage tank testing guidelines for each state and provides links to the important documentation that should be reviewed prior to any tank testing to API-650: Welded Tanks for Oil Storage, API-653: Tank Inspection, Repair, Alteration, and Reconstruction, and STI-001: Standard for the Inspection of Aboveground Storage Tanks.




Figure 1: Aboveground storage tank testing.


Review of Above Ground Storage Tank Testing Requirements

The requirements for aboveground storage tank testing are largely driven by state environmental laws and regulations. While states generally defer to API-653 and/or STI-001, each state’s regulations must be fully understood by the tank inspection company to ensure that all local regulations are satisfied. Some important tank testing considerations for each state are provided below.



Figure 2: Tank floor testing with acoustic emission.


Storage Tank Testing in New York State


Tank testing requirements in New York State (NYS) are outlined in New York Codes, Rules and Regulations (NYCRR). The specific documents are:

-

6 NYCRR Part 598: Chemical Bulk Storage (CBS) Handling and Storage of Hazardous Substances – Section 598.7 Aboveground tank systems – inspection, and,


2. 6 NYCRR Part 613: Petroleum Bulk Storage – Section 613-4.3 Inspections and leak detection


The NYS CBS regulations require that tank testing be performed on an annual basis. This is largely a visual inspection to identify major tank issues that may require follow-up non-destructive testing. This tank testing includes non-destructive testing (NDT), visually inspecting for cracks, areas of wear, corrosion, poor maintenance and operating practices, excessive settlement of structures, separation or swelling of tank insulation, malfunctioning equipment, safety interlocks, safety trips, automatic shutoffs, leak detection, and monitoring, warning or gauging equipment which may not be operating properly.


The NYS CBS 5-year tank inspection requirements include:

- Examination of exposed piping, joints, welds, and connections for misalignment and tightness,

- Structural inspection of representative sections of pipes

- a tightness test of any connecting underground pipes

- inspection and assessment of all ancillary equipment

- an identification of system deficiencies that may result in a leak

The NYS PBS regulations are generally similar, but the above-referenced document should be reviewed for specifics.


Figure 3: Direction vectors for internal robotic tank floor inspections


Storage Tank Testing in New Jersey

Aboveground storage tank testing regulations in NJ are outlined in N.J.A.C. 7:1E, “Discharges of Petroleum and Other Hazardous Substances” (DPHS), specifies testing and inspection requirements for aboveground storage tanks over 2,000 gallons in capacity which contain hazardous substances identified pursuant to N.J.A.C. 7:1E-1.7.




Section 7:1E-2.16 Integrity Testing describes in detail the inspection policy for aboveground storage tank testing in New Jersey. Field-erected steel aboveground storage tanks with a storage capacity greater than 2,000 gallons shall undergo integrity testing in accordance with the following inspections:


- Tanks at atmospheric pressure shall be tested per API-653,

- Tanks under pressure shall be tested per API-510 or ASME Section VIII

- Shop-built steel aboveground storage tanks greater than 2,000 gallons shall be tested per API 653 or SP001

- Fiberglass reinforced plastic (FRP) aboveground storage tanks testing every five (5) years with acoustic emission testing, in accordance with ASTM E1067, in combination with internal visual and external visual inspections.


Storage Tank Testing in Pennsylvania

Aboveground storage tank testing in Pennsylvania is administered by the PADEP and detailed regulations are set forth in Chapter 245: Administration of the Storage Tank and Spill Prevention Program.


Pennsylvania is unique because a PADEP certified tank inspector is required to perform the inspections. In addition to an API-653 inspector certification, a PADEP tank inspector is required to pass an exam administered by the state that focuses on Pennsylvania tank inspection regulations and various nuances for API, STI, and other inspection codes. PADEP tank inspectors are certified as IAF and/or IAM tank inspectors. The IAF and IAM pertain to field and shop fabricated tanks, respectively. In addition to the PADEP certified tank inspector, the company performing the inspection must also maintain an PADEP company certification. PADEP aboveground tank inspection findings are classified as:

- Major Modifications – alters design and may affect integrity of AST system or facility; and affects tank portion.

- Minor Modifications – does not alter design and may affect integrity of AST system or facility; does not affect tank portion.

- Maintenance – does not alter design and does not affect integrity of AST system or facility.


In addition to the standard API-653 internal/external inspection report, a PADEP specific reporting form is required to be completed and submitted to the state by the PADEP tank inspector and certified company.



Storage Tank Testing in West Virginia

Aboveground storage tank testing in West Virginia is regulated by the West Virginia Department of Environmental Protection (WVDEP) and must comply with Aboveground Storage Tank Act at W.Va. Code § 22-30-6.



In WV, "Aboveground storage tank" or "tank" or "AST" means a device made to contain an accumulation of more than 1,320 gallons of fluids that are liquid at standard temperature and pressure, which is constructed primarily of nonearthed materials, including concrete, steel, plastic or fiberglass reinforced plastic (FRP) which provide structural support, more than ninety percent of the capacity of which is above the surface of the ground and includes all ancillary pipes and dispensing systems up to the first point of isolation. In WV, tank testing must be performed by:


- WV professional engineer

- API-653 Inspector

- STI tank inspector.


Additionally, storage tanks are categorized as Class 1 and 2. For Level 1 AST systems, the initial inspection conducted in accordance with 47 CSR 63 and subsequent inspections every third year thereafter shall be completed by a qualified person as described above. For Level 2 AST systems, the initial inspection conducted in accordance with 47 CSR 63 and subsequent inspections every fifth year thereafter shall be completed by a qualified person as described above.


Summary

In addition to the tank testing guidelines published in API-650: Welded Tanks for Oil Storage, API-653: Tank Inspection, Repair, Alteration, and Reconstruction, and STI-001: Standard for the Inspection of Aboveground Storage Tanks, tank inspectors must be familiar with state regulations that may exceed the cited inspection requirements. This article presents slight, but very important, nuances between the state rules for tank testing.

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