Tank Talk - Alaska's Bulk Fuel Podcast

STI SP031 with Experts

• Integrity Environmental • Season 3 • Episode 6

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In this episode of Tank Talk, host Shannon Oelkers is joined by representatives from the Steel Tank Institute/Steel Plate Fabricators Association (STI/SPFA) to dig into Standard Practice 031 (STI SP031) - the industry guidance for repairing and modifying atmospheric shop-fabricated steel tanks. As steel prices rise and logistics become more complex, especially in places like Alaska, repairing existing tanks has become a more attractive and necessary option. We cover what owners need to know - responsibilities, warranty impacts, contractor qualifications, and how to keep your SPCC plan compliant. Whether you're managing tank assets or writing project bids, this episode helps you get it right the first time. 

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Haley Hall:

Welcome to Tank Talk with Integrity Environmental. Join us as we sit down with founder, principal consultant and bulk fuel storage expert, Shannon Oelkers, to explore regulations, safety and essential tips for navigating the bulk fuel storage industry. Join us as we explore the unique joys of work and life in Alaska with industry experts, including our team, vendors we work with and the companies we support.

Shannon Oelkers:

Hi, welcome to Tank Talk. This is Shannon Oelkers, and today we're going to be talking about the Steel Tank Institute Standard Practice 031. And there's a very specific reason for that. With soaring steel prices and especially in Alaska, where logistics can be a big part of the cost of a tank, we're seeing repair to damaged shop-built tanks, especially the larger, more valuable ones. 20,000 gallon size more often, more frequently. So suddenly we're interacting with this Standard Practice 031 a lot more than we ever have. It is a tank repair standard that covers repair modifications to atmospheric shop fabricated tanks made of carbon or stainless steel and it is intended for tanks storing flammable and combustible liquids like the fuel that we all store.

Shannon Oelkers:

So I feel like there is a gap in our knowledge about this standard, especially for owners, project managers, contracting officers and other people who are responsible for managing capital expenditure or improvement projects, and so I have asked Joe Mentzer from STI SPFA and Craig Fletcher from Fletcher Consulting Inc to join us today and answer some questions that I have had about the STI SP031 standard and then hopefully also provide answers that those of you that are in that project management contracting officer role, so maybe that you can understand the parameters and how this is used. So, Joe, Craig, thank you for coming on Tank Talk again, I really appreciate having you here. I was hoping you could introduce yourselves, give us a little bit about your background and how you got into tanks before we dig into STI SP031.

Joe Mentzer:

You can go first, Craig, this time.

Craig Fletcher:

My name is Craig Fletcher. I'm the principal of Fletcher Consultants. We're a small Oakland, California-based firm that does a lot of that provide environmental consulting services of a wide variety. Some of the services we provide include preparing SPCC plans, conducting and performing SP001 certified inspections, helping companies that have large tank fleets whether they're national laboratories or military installations, setting up programs for that, as well as doing other environmental consulting things, including hazardous waste facility permitting and many other aspects of the environmental consulting world.

Craig Fletcher:

One with respect to my background, our firm's been around since 2002. Prior to that, I was a principal environmental engineer with the Pacific Gas and Electric Company, where I worked in the power generation industry for a number of years. During that time, I worked at a power plant where we had about 18 million gallons or so of petroleum storage on site, so I got a little bit of experience there on the front lines with that. Prior to that, I was in environmental consulting at another smaller facility and then before then, I was in grad school and before then I was actually working for Chevron Exploration Exploration Geology. So that's a little bit about my background. The part about getting into tanks and doing that. Really I became an inspector in 2009. And we recognized at the time, with the changes in the SPCC regulation, that we knew that tank inspection was going to be an important part of not only understanding and preparing SPCC plans, but also another avenue where we could learn more about tanks. That's when I first became certified as an inspector. I've been doing it ever since.

Joe Mentzer:

My name is Joe Mentzer. I'm the standards engineer for the STI SPFA, which is the Steel Tank Institute Steel Plate Fabricators Association. That's an organization that has been around for many, many years. I've been here for about six years now. Prior to that I was a consultant. I worked in most of the upper Midwest mostly Wisconsin but the surrounding states and I helped my clients store and handle regulated stuff certainly petroleum, but other chemicals worked in the printing industry, pharmaceutical industry, food industry, automotive fluids all sorts of things. I initially started off doing cleanups but one of my very smart clients said actually he'd like me to design systems so they didn't leak. And one thing led to another and I've been dealing with all sorts of industry since then and just decided to try something different with STI.

Joe Mentzer:

I have been an SBO1 inspector since July 2001. In fact, I think I attended the first class that ever certified an inspector and, like I said, I've gotten involved in several industries. It's taken me some very interesting places. I do have a degree in engineering. I'm a mining engineer. Went to Madison, Wisconsin.

Shannon Oelkers:

Is there like STI inspector numbers? Are you like in the single digits or something like that?

Joe Mentzer:

So the first series of numbers I am inspector 112 on the first list and they started with 100. Yeah, the first class, I think, was 16 people. Oh, it was for the state of Wisconsin An interesting story. The state paid for the class. There was a maximum number of people, I think it was 20. The guy who ran our state program his name, was Sheldon Shaw, a good, frugal Wisconsin guy. There was three or four spaces open and I was working with them on some installations. Hey, you want to come get certified, just bring donuts. So I got actually certified for three boxes of donuts.

Shannon Oelkers:

Just bring donuts. That's a deal it's paid for.

Joe Mentzer:

He didn't want the three or four spots extra to go to waste, so he invited me.

Shannon Oelkers:

I wish my inspection had been three donuts or three boxes of donuts.

Joe Mentzer:

I don't live far from Madison, so yeah, I got to go. But yeah, I've got the card. It's 110 or 113, but I was the first batch of inspectors.

Shannon Oelkers:

Well, and I know you, gentlemen, because I've taken classes from you, Joe, at both the API annual conference, and then you and Craig together, were part of the team that taught me when I got my STI certification, which is a much higher number than 112 back in 2022, I think but I really appreciate you coming here to talk about SP031. So let's start off with what the history of the standard is. When did it come into being and why was it created?

Joe Mentzer:

So SP031, I just kind of give you an idea of our numbering sequence, the first two numbers of the year. So it was 2003, and it was the first standard produced that year. We produced SP-001 in 2000. The original SP-001 really followed the API 653 standard, which was inspection and repair. But after they did the inspection standard it kind of determined yeah, we got to have a repair standard as well. Originally people were repairing the shop-built tanks to that API 653 standard.

Joe Mentzer:

The thing is there's some unique aspects to the construction of shop-built tanks. If you ever get a chance to see a tank shop, they're really, really amazing at how they take steel, roll it, form it, fit it, line it up, weld it. And I've been to shops where there's a pile of steel there first thing in the morning and late in the afternoon it's sitting there in front of the paint shop ready for a coat of paint. They do this very quickly but there's some unique ways that they assemble things that you have to take into consideration when you're making repairs. And the Steel Tank Institute we support our products. So we created this repair standard. We relied, we referenced back to the API standard on a regular basis. This is a good standard, but there are some very specific things in the SPO 31 standard about what you can and cannot do and how you address repairs in certain areas of the tank. So it was needed. So we produced it. You address repairs in certain areas of the tank, so it was needed so we produced it.

Shannon Oelkers:

So when you read through the standard, Joe and Craig, it has some pretty specific owner responsibilities. Can we talk about what the owner is responsible for under this standard?

Craig Fletcher:

Sure, Sure, I can talk about this one a little bit, Joe. I mean, essentially it's very similar to SP-001 in terms of there's a lot of responsibility on the owner. After all, it's their asset, it's their equipment, right Under the standard. They're responsible for making sure that they're following federal, state and local codes and regulations. They're making sure that people that are working on the tank system know what the hazards are, and oftentimes it's almost universally, because tank repairs generally are a specialized field that requires certain skills that are out there. They're going to need to reach out to specialists and, whether that's an engineering firm or a welding company or a petroleum contractor or whoever, that's where they're going to really need to reach out for that. So there's a lot more to it than what I just described, but realistically it's kind of a team approach generally.

Joe Mentzer:

And bear in mind, with tank repair, the preparation before is almost more work than actually the actual repair itself and the proper documentation, so that the history and we're going to discuss some things about certifications and regulatory obligations If you don't get that right, it can just create headaches. So it's very important that the owner understands what they're doing and make sure that he has individuals involved that understand the process of doing it right.

Shannon Oelkers:

So understanding the process overall and all the pieces of it, and then also making sure the contractors you hire have a resume that indicate they're specialists in this and have done it successfully before. This is not any handyman, any guy that's turned a wrench. You've got to find someone who's specialized in it.

Joe Mentzer:

You're better off looking at people who repair pressure vessels, the process or the API 653 process, especially in the organization. The safety concerns the documentation afterwards.

Shannon Oelkers:

And for any tank repair, there's two pieces to it. One is cleaning and preparing the tank for people to be able to enter and fix it, and that's a whole specific set of confined space entry and how you clean it and the waste stream that is generated when you clean the tank and how you deal with the waste. And then there's the actual repair and return to service.

Shannon Oelkers:

And I believe this SP-031, it specifically deals with the repairs, not necessarily the tank cleaning. That happens before correct.

Joe Mentzer:

Yeah, Tanks can be in all sorts of places One tank sitting out by its lonesome in an area that's relatively easy to isolate and clean. When you're trying to fix the middle tank in a 12 tank tank farm, what about the other 11 tanks surrounding it? Or you're in a location that's doing all sorts of dangerous things and they have a tank. Sometimes you end up taking the tank, removing it, taking it out of the location, doing the repair and putting it back in, just because you know, and then at that point maybe you're better off just replacing the tank because you've done most of the work. I mean, it all depends on your circumstances, Although you are correct, because I've seen more people call about repairing complicated, larger tanks because of lead time to get it and then just the cost overall.

Shannon Oelkers:

Lead time cost and then, just for Alaska especially, the shipping costs have gone up so much to get a 20,000-gallon tank created in Washington at Greer and then shipped all the way out to Western Alaska. It's significant, so these repairs are starting to make sense economically. So I wanted to talk about how repairs or modifications can affect a tank listing or warranty, because there's a big warning at the beginning of 31 that says this can impact your listing or warranty. What should owners be aware of if they want to maintain their tank listing and or a warranty, if it exists still?

Joe Mentzer:

So the tank listing part is tricky. If you look in fire code it says that the tank has to be built for the purpose it's intended to be used and basically you have to provide documentation satisfactory to the authority having jurisdiction that this tank's going to work for what you're using it for, or Southwest Research. That works, but it's not the only way. That certification label gets installed at the time of manufacture and the company that built the tank hires a third-party listing agency that inspects their operations, inspects how they're building things, doesn't inspect every tank, but it keeps a good eye on how the tanks are being built and in following those rules, that manufacturer has then the authority to add that listing label and that's put on at the time the tank's built and the day that tank leaves the shop, that tank is good to go. Now what happens to it after it leaves the shop? That's where things get tricky.

Joe Mentzer:

When you're dealing with tank repairs, you really have to reach out to the regulators, especially at the local level, and here's my problem. Here's what I'm going to do. I am going to use this recognized industry standard and these recognized, these certified individuals. They're going to oversee things and at the end they're going to write a document that says this tank's good to go and you got to make sure your regulator's good with that. In most cases you have the SPO 31 standard and the API 653 standard. Those are the standards used in the industry and it has certified people involved holding their thumb in the air. That's good enough to satisfy the authority having jurisdiction. Somebody qualified has says this tank is good to go. Originally it's the listing label you have on the tank. Now it's a qualified inspector that says between the listed product that originally showed up and the modifications made and all these steps followed, this tank is still good to receive product. So that's the listing part. The warranty part's a whole lot more tricky.

Joe Mentzer:

Because the warranty.

Joe Mentzer:

Warranties can come from manufacturers or from third-party warranty providers, but they're warranting the product that the manufacturer produces. So either the manufacturer says, here you purchased my product, I'm going to say for one year, you're good for material and workmanship issues, or they can buy a policy from a tank insurer. The Steel Tank Institute does not insure tanks. There is an organization called the Steel Tank Insurance Company that we do work with. That does so. We're different entities but they're still only warranting the original manufacturers.

Joe Mentzer:

The purchaser of the warranty is the tank manufacturer and so if you go start messing with the tank and changing things, well, that isn't what the manufacturer built, so that may not be warranted. I mean, I'm not going to guarantee you that it's going to void the warranty, but I can't guarantee you the warranty is going to be there. So you have to be really careful, you know. And then why are you changing this tank? Are you repairing damage? Did something else happen Again? So yeah, most manufacturer warranties are only one year. The extended warranties that go on longer, that's very difficult to establish. I mean, if it's like adding a minor fitting and a problem later didn't affect that fitting, the warranty may still cover you. But I can't guarantee anything. I did talk to one warranty provider and that's what he told me. So yeah, you're kind of putting things at risk.

Shannon Oelkers:

So functionally if you're going to repair the tank, if there's somehow a warranty in place. Most of the times I've seen this 31 applied. The tank is well past that one year, but I did want to talk about it a little.

Joe Mentzer:

If you have the original manufacturer make the change, then you still might be in good shape.

Shannon Oelkers:

Let's ship it all the way back to Lakewood.

Joe Mentzer:

Well, maybe it's more down here in the Continental, but there are some tank manufacturers that have service departments.

Shannon Oelkers:

Oh, that will come and actually do it.

Joe Mentzer:

They not only build the tank, install the tank, they service the tank. That's good to know, and occasionally we do have a case where somebody ships a tank, buys a tank, ships it and all of a sudden we came up one fitting short. Can you please come and install one more fitting? And some guys will, some won't.

Shannon Oelkers:

Okay.

Shannon Oelkers:

So, Craig, how does that play into the SPCC? If you're going to have a tank repaired under 031, do we need to alter the SPCC at the same time? Or update amend.

Craig Fletcher:

Yeah, I think that has to depend on what the scope of the actual repair or modification is. Is it's really kind of the part that you can sort of get into that world of? Does it have a material impact on the ability of the facility to discharge from the property? It's probably a site specific thing based on what they're actually intending to do. Just one last thing about the listing issue is that you know, in current practice.

Craig Fletcher:

In current tank installation practice, virtually every tank that's going to be installed nowadays of the shop fabricated design is going to typically have some kind of listing afforded to it, whether a CUL-142 or Southwest Research. We don't normally see people putting in custom specialized tanks that have to go through some really elaborate design review by the fire department to determine whether they're suitable. That's just not really a practical thing, right? But if you are going to go in and do something like welding on a UL listed tank or cut a new hole in the top for another fitting, you're definitely going to be affecting the listing status of that tank. So in California and other jurisdictions where that listing is so important to fire marshals, that can really affect your ability to what may work in that situation. However, that's going to vary by your local jurisdiction. So in some cases you know it may be something completely different. Your mileage may vary put it that way with your local jurisdiction.

Shannon Oelkers:

So maybe a good catch-all, if somebody's sitting in the project management seat, is that they should let their SPCC writer know that they're modifying the tank so that, if it applies, they are not leaving it out of an SPCC amendment if it's required.

Craig Fletcher:

Definitely.

Shannon Oelkers:

Okay, so we had this question come up actually just a month or two ago. Can you still use SP31 if you don't know the original construction details for your tank, like the labels? It's fallen off or is illegible? We're not really sure if it was a UL-142, but we're assuming. Can you still apply the 031?

Joe Mentzer:

You know the standard kind of addresses that you have to look, you get back to that listing issue. If you don't know the construction standard, how is the tank listed? And also what's the tank holding and are you required to have? So it doesn't prevent you from using it, but I guess in the circumstance that you're using the tank you have to know that it's suitable for the purpose that it's being used for. Also, you have to have that discussion with the authority having jurisdiction. If you told the authority having jurisdiction I don't know what the listing is on this tank but I want to change it he's probably going to go to the. Well, you don't know the listing on this tank, then why are you using it in the first place? So it gets a little tricky,

Shannon Oelkers:

It's Alaska so we use whatever tanks we can find.

Joe Mentzer:

Yeah, the standard says you can, as long as you understand the construction of the tank and you take the proper steps. But we go back to that thing Craig talked about. The owner's got to make sure that the tank is suitable for use, and that also even goes back to the SBO. It's up to the owner to make sure things are suitable for use.

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Joe Mentzer:

Now I will tell you I have seen a lot of unlisted tanks used for storing things that aren't regular, like asphalt cement, because it's not a liquid. And you look at them and they're really UL tanks. And that's because the UL standard is a good shop fabrication standard. It works well in a shop. So does the API 12 series. Other industries just use it because it's a recognized standard. They just don't pay the extra money to buy the UL label.

Shannon Oelkers:

We do see that sometimes where it was constructed for some other purpose, but now they're using it for fuel.

Joe Mentzer:

Yeah, I've also seen some tanks built in like South America, where some very skilled metal workers collected a bunch of scrap steel and put something together. It's like, oh, that's not even you know. Great work, guys, but not even close.

Craig Fletcher:

And, getting back to your example, I would think too that you are going to have tanks that are not have a listing right. We talked about API 12F or API 650, appendix J. Those are not true listings but they are recognized standards. So that is definitely allowed and it is very common to go out to older facilities in particular where you almost have to make some kind of assumption based on your best examination. Was it built to a shop fabricated standard? Probably. Which was it? Well, I did some steel thickness testing on it and I know by the design this is probably following a UL standard, but I can't say for certain. But I think those are kind of where a certified inspector or other knowledgeable party may be helpful in guiding that. You know the use of that. But I think SP-031 certainly allows discretion for owners to be able to use that in those conditions where it's not.

Joe Mentzer:

You got to keep the regulator happy.

Shannon Oelkers:

So what I'm hearing is, if you have a tank and you're uncertain of its construction standard, either due to age or loss of record keeping, it may be wise to include a certified STI or API inspector on the team that's helping you with this capital improvement project, and or a mechanical or structural engineer that's familiar with this product, the type of use and the fire codes, to be able to give the blessing from the engineering side of things rather than just relying on assumptions. Okay, that sounds good. I think those are good, actionable steps to take. If you've got a tank, you're not sure of its history, then you can just add those to the team. I was wondering if you guys could go over some common repairs or modifications that do occur in shot belt tanks, because I do think that sometimes the standard is brought in and maybe I don't know like. I'm just curious, like what are the most common versions of repairs and modifications that occur under it?

Craig Fletcher:

It's not particularly common, at least here in California, because many times it's maybe more cost effective to simply replace the tank. But I can tell you in other cases it ranges a gamut from something as simple as weld deposition, like puddle welding to fill in. If we're doing an internal inspection, we have corrosion pits. That's pretty common. If we have gone into a tank or we've seen reworking substandard welds or cracking areas of cracking those are pretty common. Or if you do have areas where you have corrosion or damage to the tank, replacing certain sections using either patch plates or insert plates, patching over it or inserting a new piece of steel to match the curvature there. So I would say those are some of the most common ones that you would probably encounter out in the field Particularly.

Craig Fletcher:

I'm just trying to think a little bit about some of the challenges you face in Alaska and what the genesis of these repairs are. But I would suspect some of those have to do with corrosion and that or that's probably the most common one there, I would think. But I don't know. Joe, you got anything to add to that?

Joe Mentzer:

Well, in the Midwest the issue is bottom replacement on vertical cylindrical tanks, and that's because people let the leaves and junk build up in the bottom of their dikes and let them hold moisture in the bottom inch or two or just all beat up, rotten away. So that's not an uncommon repair. Occasionally get some localized corrosion on the shell for whatever reason. Usually again it's something wet, got up against the side of it and they ignored it for too long. And, yes, they put a patch plate over the top and make sure that it's sealed up to the original tank. The original tank hasn't failed, but it's just got a thin spot. So, yeah, those are the common repairs.

Joe Mentzer:

Occasionally I've done some insert patches again due to really just poor housekeeping on the outside, on the inside that's where the bottom replacement comes in. And then occasionally adding a new fitting on top of the tank. Change in service, change in operation we need another fitting. But again and Craig hit the point too often Occasionally, adding a new fitting on top of the tank Change in service, change in operation, we need another fitting. But again and Craig hit the point too often, once you've got the tank cleaned and ready to go, yeah, well, you know, instead of adding this new fitting, why don't we add a tank that's 5,000 gallons bigger, and then that tank gets removed and you get a new tank.

Shannon Oelkers:

Yeah, some of the ones we've seen lately. I've seen a couple of steel saddle support repairs where the steel supports were corroding and failing to support the tank. There was some buckling. And we've also seen them removing bottom appurtenances and moving them to the top. Like the tank was older and it has a water draw on the bottom, but they maybe want to use it for aviation, so they remove that, patch it up and then move something to the top rather than having it extrude from the bottom and then, of course, the corrosion patches. That's the number one reason that we get 31. That's usually why the tank cannot continue in service without a repair, and that's what's driving the use of this 31 is that they can't afford to replace it. Patching it is probably cheaper, or they've determined it to be cheaper and they move on. I also had a note here. Are there any modifications that are not covered by 31? And if there are, why aren't they covered?

Craig Fletcher:

So there are some provisions under Go ahead, Joe, as I say there really is.

Joe Mentzer:

Sbo 31 says here's the repairs you can make and here's the modifications you can make. So you got to be careful. You can't, and you also have to have some recognition of the original tank listing as well. You know things like increasing the size of the tank that's not covered under this standard, turning a horizontal tank into a vertical tank Again, that wasn't how it was designed to be. There's things that an engineer can do. The term is called a convertisontal and Craig taught you that one Convertisontal.

Shannon Oelkers:

I have photos of a few of those that I have encountered't go redesigning the tank or, you know, changing its original intent significantly in a repair.

Joe Mentzer:

That's where you maybe need a new, probably need a new tank. At that point you're probably better off just buying a new tank. Or you need an engineer and then there's certain damage that we can't account for in repair. You know the tank I get this tent. My tank's been in a fire, it's been baked, great it's done. Nobody, nobody's going to say that tank's good to go.

Joe Mentzer:

Your insurance is probably going to cover it.

Joe Mentzer:

Yeah, yeah. Or what's the other one? Guy had a tank in a underground vault. The vault filled with water. The tank floated, bent water. The tank floated bent all of the fittings over on top. Just you know how can I fix it? You can't, don't even waste your time. So yeah, there are absolutely limitations.

Craig Fletcher:

So I would say too, Shannon, and some of that within the specific portions of it. There's other examples where things where you're going to need engineering assistance, You're going to kind of step outside of the scope of SP-031 for at least parts of it, If you're designing a new anchorage system for a tank like you're going to put new anchor chairs on a tank or doing it, you're going to have to have some engineer involved to help you with the structural aspects of it.

Craig Fletcher:

If you have pipe penetrations that are greater than 12 inches below the liquid level, now you have to start thinking about what are we going to do to reinforce that location and at that point then again you're back into some more of the engineering side of it as well. So, changing the height of a tank, adding another course to the top of the tank, that's not covered under the run-of-the-mill SP-031 standard. It can be done, but it's going to be outside the scope of the standard. So I think and Joe can speak to this but I think most of what SP-031 is for is to really address the common repairs and alterations you might have a tank, give the owner and the industry guidance on what can be done and what's not allowed to be done, including restrictions on where you can do certain welds or repairs. But it certainly can't account for every possible thing that's out there, particularly for major modifications for tanks. Yeah, Okay.

Shannon Oelkers:

So if you're sitting in that project management chair, it's good to be aware that there are limits to what can be handled under the 31 standard and if you need to go outside of them, that's fine. But you've got to have some kind of engineering presence to guide that and to make sure that the contractors are meeting all of the different engineering standards and fire code requirements and regulatory requirements that go with those major repairs or revisions. And the 31 is limited to some very specific ones and you should know which ones they are. If you're going to be modifying a tank Okay Right, that sounds good. Related to that, tank repairs require multiple types of qualified personnel. I was wondering if you guys could review what kind of contractor qualifications might be needed to perform the repairs and the inspections, because the SPI, sc-31, it talks about what you need to have for repair and then what you need to have to qualify for inspection. Could you guys address those two pieces?

Joe Mentzer:

You need an SP001 inspector because they have to inspect the tank and one of the important things is make sure you thoroughly inspect the tank before you perform a repair, because the last thing you're going to do is fix this one little spot over here and oh wait a minute, you got this huge problem over here.

Joe Mentzer:

Any welding done, you have to use a certified welder, so make sure that that welder is qualified. You may have to do some non-destructive testing after the repair is made and, depending upon the testing, you got to make sure that the person doing the testing is qualified to do that testing. And then you may have to test the integrity of the tank. I don't think there's any particular qualification to do an integrity test, but make sure the person knows what they're doing, because otherwise they can do more damage. We've seen that happen a few times.

Joe Mentzer:

The problem is each repair can be a little bit different, so that the people involved may need to be a little bit different. But these are kind of specific skills. You know, I've seen lots of tanks. Oh, you know this beautiful four-inch perfectly square patch on the end of a tank welded in wonderfully yeah, that's great. Minimum patch is six inches, supposed to round the corners. That's the sort of thing you see when people don't understand the standards involved in them.

Craig Fletcher:

I'd also add one thing to that too, shannon, that you know, under the standard for people that can qualify to do repairs, that also includes welding personnel at a facility that actually manufactures STI, API, ul or Southwest Research Tank. So those fabricators, although they're not explicitly certified welders like we think under ASME or other things, they are also qualified under the standard to make those repairs. So there's some specific language in the standard who can do what? So you definitely want to follow that, particularly if you're maybe a contracting officer or someone else trying to put together a spec package or a bid package for someone, making sure they know who the qualifications are, because you wouldn't want to go through this whole process and have someone who's not qualified, right?

Craig Fletcher:

No, similarly, the inspections can be done, like Joe mentioned, from an STI certified inspector. Inspections can be done, like Joe mentioned, from an STI certified inspector. It can also be a API 653 inspector or it can be a person who's employed by a manufacturer of people that make STI or API or UL tanks or Southwest Research tanks. So there's a little bit more of play in there, designed for because I know in my experience trying to get sometimes back to the fabricator. If you can to help you can be a good approach if they've already perhaps built the thing. Having said that, your mileage is going to be different up in Alaska, where you're at remote locations where you won't have that luxury.

Shannon Oelkers:

So that's kind of the other basis it's good to cover, though, because we have a pretty significant listenership in the state of Washington and the state of Oregon as well, and they can absolutely interact with their manufacturers. They're present All right. So if contractors are following SP 31, they should be providing a final report or record of all the modification, repairs and testing that occurred. I personally can attest to a wide interpretation of what this report should look like and include. Could you maybe review what a final report should look like? I'm hoping that these contracting officers and project managers and owners could be set up to expect a certain quality or a certain what they need to get back in that report to show regulators and the SPCC plan writer that the repairs occurred, because I have seen everything from a one-page checklist that's hand-filled out with a mechanical pencil to a proper report with lots of supporting documents. So maybe let's go over what a proper report would look like.

Craig Fletcher:

I can talk a little bit about that one. And basically, getting back to the contracting officer or someone trying to set up a specification, the standard itself has some specific requirements. It says that it has to show that the repair or modification that was done was done appropriately. The testing and remember, for each type of repair or modification you're going to do, there is an inspection and some type of testing required for that. It's going to vary based on what the scope of the repair is. Some may be just a simple visual inspection, some may be more involved. So this is all covered within the standard. So I would think that if I was a contracting officer having access to what the standard explicitly says, if I'm trying to set that up, I would definitely include that.

Craig Fletcher:

There's also a discussion of how in SP-031 talking about is the design and meeting the standard and code compliance after the repair or modification was done and there should be at least some overview of what was some description of what the repair or modification was done. That seems pretty straightforward and there's documentation that's complete with that. So we do see this on the 653 side where they have. There's similar requirements there. But Appendix B of SP-031 has a final inspection form in the back there that can help guide that documentation 001 inspection.

Craig Fletcher:

Typically, what we want to include in a report like that is a summary of what was done, what testing was done, what repairs were done, the test reports, whether they passed or failed or what the results of it were, sketches of the area that was repaired or modified and photographs of what the work and any other materials. You may include the qualifications of your welders or you may include other things of that nature that apply to the actual modification or repair that's done. But it's a very important step and as an owner, you clearly want that. You definitely want that in your back pocket for your own protection, because if you have had repairs done, I would expect that someone at a regulatory agency may request that, because they'll probably look at your tank files as part of the SBCC plan inspections. So that's kind of what I would certainly say.

Joe Mentzer:

You've hit one of the important points. At some point, some qualified individual is going to look at this tank and say, hey, what happened here? I have my list and my list says you know one is there should be some summary or finding on the original. Why are you doing this repair? Maybe it's back to a tank inspection report where problems were listed, or you know the request that I needed out of fittings for some reason. But why is the repair done?

Joe Mentzer:

Certainly, documenting the original tank construction standard, whether you've documented it or this is what you believe. But that AST record, the original one's good and you may need an updated record depending upon what changes are made. Certainly you know a summary of everything done by the repair firm at this time. So that way, in 20 years, when someone does the next formal inspection, why is this patch here? Oh, okay, here it was documented. You know, again, got to throw some crumbs out for the next inspector who's going to be trying to figure out what you're doing. Certainly, yes, the certifications for people involved, the results of any testing, depending upon the level of testing. If you do an integrity test, that record should be kept. Certainly, if you've done some testing, you want credit for it. And then finally, if the authority having jurisdiction, like Craig, said they may be interested, they may need to come and reinspect the tank before it's put into service and their sign off is a good thing, but the paperwork can be just as much work as welding a patch on the tank.

Shannon Oelkers:

Or more. So keeping it for the life of the tank is important as well. Like this is a document that cannot be forgotten or left in an email. It absolutely has to be included in the file for that specific tank once it occurs.

Joe Mentzer:

I learned from my predecessor it's good to leave notes. She left me some things and things. Oh yeah, that makes sense now. So leave the next individual some information to help them do their job.

Shannon Oelkers:

I think with the STI standard, what does make it a little more difficult is that you've got 20-year inspection intervals for a class one tank and in 20 years you can have multiple turnovers in a job, and so we definitely focus on keeping it for the life of the tank, keeping it hard copy where the tank lives, not just in digital land but in multiple places, and then our firm, of course, keeps records forever so you can go back to us even if you didn't keep it internally, which has happened sometimes. So we've talked a lot about writing bid packets or specification packets. Do you guys have any pro tips on how to write this standard into a proposal or an RFP or a spec package to make sure that when you send it out, the bids you're getting back are going to be compliant with this standard?

Craig Fletcher:

I think on that. Shannon, you're going to have to have somebody on the owner's side have access to SP031, because that's really that's your guideposts on what you are required to do. It's not available anywhere else. I mean it's going to come straight out of that standard. So having that is certainly one, and trying to incorporate to the extent you can in that bid request the specific items that people have to do when they are doing repairs and modifications to tanks.

Craig Fletcher:

The other part of it too is that and I don't know, I'm sure it depends on the actual bid process or spec you're preparing is that it's not particularly common to have the petroleum contractor or the repair company be the same as the inspection company.

Craig Fletcher:

So in that case there is a benefit to having some separation there. That's another consideration, because there could be some conflict of interest issues with that. So that may be something for procurement officers to think a little bit about how we're going to get this work package together, who's going to do what and who's going to retain the individual parties for that. So in my experience, relying solely on a contractor to do everything, when we actually and you know this as a plan writer is that we need something that we can hang our hat on to go with our SPCC plan, which is a regulatory compliance document. So that's where we want to end up at the end of the day, to be able to have that. So that's kind of what I would think might be something worthwhile for those who want to do bid requests for something like this to keep in mind.

Joe Mentzer:

There are some firms that do regular repair on tanks or industrial stuff and understand what they're getting into, and it's certainly it's good that the person that you're contracting understands what they're getting into. Getting them to come and have a look at the tank is always important. Making sure they understand the rules that are in play at the facility, depending upon the. You know, if you're working deep in the heart of an industrial facility, they can have some pretty significant rules on what you can and cannot do. It increases their time and their effort, so you got to make sure they understand the circumstances associated with it. And making sure they understand the hazards associated with either the materials they're working around or materials they're working with is important as well.

Shannon Oelkers:

So providing a good, clear description of the facility, the products they're working with and the general environment. Making sure that you're listing out the qualifications needed for the actual repair and maintenance, separating the inspection from that to avoid conflict of interest. Spending the couple hundred dollars to actually buy the SP31 standard and reading it prior to starting the project. And then I think I would add, making a nice clean list of deliverables and say final report, including photo log, including report data, including non-destructive testing results in PDF or something like that, so that it's all together. It's not 27 emails of 27 documents which we have definitely gotten before. So assembling it into that kind of a final report, okay, those are all really good tips.

Shannon Oelkers:

I agree with you that just purchasing the SP-31, it is not that long, it is not that complicated, but you do need to have it if you're going to be doing repairs to a tank at your facility. Okay, so I think that's everything I have for SP-31. Does STI SPFA have any additional resources for our listeners if they want to learn more about this standard, sti SP-31?

Joe Mentzer:

Actually, on August 11th we're doing a webinar on SP-031 and more so on things people do wrong with it, so that one is coming. We've done that. One did that out for the Coupa folks in California did it down at the National Institute of Storage Tank Maintenance recently. We're going to do that as a webinar coming and our website does have the Frequently Asked Questions section, which does address some things. That's certainly a good place to look. The whole STISPFAorg website is a great place for information on storage tanks how to properly maintain them, how to properly operate, how to properly repair them. So yeah, there is some information available and talking to a qualified inspector certainly helps. They should understand that the API guys, the STI guys it's similar repairs.

Shannon Oelkers:

Great. Thank you both so much for taking the time today to go through that standard with us. Like I said, we're just seeing it used so much more. I'm definitely going to tune in for that August webinar because I think it does help to know what to avoid and to be aware, and so I would encourage all of my listeners. And then to clarify we're recording this in 2025. So that'll be live August 11th of 2025.

Joe Mentzer:

10 am Central Time.

Shannon Oelkers:

Ooh, 10 am Central Time, which would be what 6 am 7 am Alaska Time. I thank you both so much for coming on. I really appreciate it. Do you have any final words before we log off for today?

Craig Fletcher:

No, we're always happy to answer questions off for today, no we're always happy to answer questions, so if anybody has anything, I appreciate it. Thanks for having us. Awesome, yeah, thank you for having us.

Shannon Oelkers:

Thank you both for coming. I just appreciate having both of your expertise. It truly was a pleasure and just wonderful to hear all this stuff and learn. I appreciate it so much.

Joe Mentzer:

Thanks, happy to help.

Shannon Oelkers:

Hi there, this is Shannon Oelkers and, as the owner of Integrity Environmental, I wanted to take a minute here at the end of the podcast to make sure that you knew the following this podcast is for informational purposes only and should not be considered legal or regulatory advice. We are not responsible for any losses, damages or liabilities that may arise from the use of this podcast. This podcast is not intended to replace professional regulatory or legal advice, and the views expressed in this podcast may not be those of the host that would be me or Integrity Environmental. Thank you very much for listening and if you do need professional regulatory advice, we'd be happy to help you as part of our consulting services.

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