Limiting a tank's capacity
Limiting a tank's capacity
(OP)
Due to a EPA request, I have to physically and permanently limit our fuel oil storage tank from 1 million gallons to 985,000 gallons. Level indicators and administrative controls are not acceptable. I can find no reference in API on reducing a storage tank capacity. How would I best limit this tank's capacity to comply with the EPI and API code? I have been asked to put concrete in the bottom and I know that is not an option, but I cannot find anything in API that backs me on this.





RE: Limiting a tank's capacity
jt
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
This is our requirement from the EPA:
2.5.3 Definition of Storage Capacity
Under the SPCC rule, if a container has the requisite capacity, it does not matter whether the container is actually filled to the capacity of the container. If a certain portion of the container is incapable of storing oil because of its integral design (e.g., mechanical equipment or other interior components take up space), then the shell capacity of the container is reduced to the volume the container might hold (67 FR 47081).
Generally, the shell capacity is the rated design capacity rather than the working/operational capacity.
2.5.4 Tank Re-rating
Shell capacity should be used as the measure of storage capacity, unless changes are
made to the design shell capacity in a permanent, non-reversible manner. For example, when the integral design of a container has been altered by actions such as drilling a hole in the side of the container so that it cannot hold oil above that point, shell capacity remains the measure of storage capacity because such alteration can be altered again at will to restore the former storage capacity.
When the alteration is an action such as the installation of a double bottom or new floor to the container, the integral design of the container has changed, and may result in a reduction in shell capacity. An addition or modification to a field-erected storage tank should be performed in accordance with industry standards and the original design specifications. Relevant industry standards include American Petroleum Institute (API) Standard 653 "Tank Inspection, Repairs, Alteration, and Reconstruction" (API-653). This standard includes additions or modifications to shell penetrations such as overfill diverters. However, even where such modifications are done in accordance with standards, the tank may not be considered re-rated to a lower capacity; the capacity remains equal to the original rated shell capacity. An owner or operator may reduce the
capacity of a tank only by changing the shell dimensions (i.e., by removing shell plate sections). Since SPCC requirements are based on shell capacity, modifying a vent, overflow, or other tank appurtenances that reduce the working fill capacity does not affect SPCC requirements.
RE: Limiting a tank's capacity
And we wonder why all the jobs are going to China, India and the likes. The EPA is a diservice to the US.
RE: Limiting a tank's capacity
I'm guessing that this is not a floating roof tank.
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
i'm sure you've already been in contact with tank vendors/manufacturers to get them involved. Chances are one of them has had to go through this with someone else before.
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
On the reasons why jobs are going to India,China etc is the short-sightedness of the Project Managers/bean counters seeing this as being cost effective BUT they never actually consider the overall cost when the job takes two to three times as long with quality taking a huge "hit". But hey perhaps they will learn when more accidents occur and hopefully they end up locked away for negligence!!
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
A new overflow is not acceptable ???/!!!!
"Shell vents, overflows, etc can be removed and are not acceptable." ???
Yup.... and someone could add a couple of shell courses in the middle of the night and get your capacity back.
It sounds like this is EPA code for "make the shell shorter"...no other solution is acceptable.
-MJC
RE: Limiting a tank's capacity
Matt
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity
Send the Nazis a large blank sheet of paper....have them draw and detail an acceptable tank farm.
Otherwise, you will have a very long guessing game ahead of you.
And people wonder why all industry has moved to China....
RE: Limiting a tank's capacity
RE: Limiting a tank's capacity