August 5, 2025 • 44 mins
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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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Haley Hall (00:10):
Welcome to Tank Talk with Integrity Environmental.
Join us as we sit down withfounder, principal consultant
and bulk fuel storage expert,Shannon Oelkers, to explore
regulations, safety andessential tips for navigating
the bulk fuel storage industry.
Join us as we explore theunique joys of work and life in
Alaska with industry experts,including our team, vendors we
(00:30):
work with and the companies wesupport.
Shannon Oelkers (00:36):
Hi, welcome to Tank Talk.
This is Shannon Oelkers, andtoday we're going to be talking
about the Steel Tank InstituteStandard Practice 031.
And there's a very specificreason for that.
With soaring steel prices andespecially in Alaska, where
logistics can be a big part ofthe cost of a tank, we're seeing
repair to damaged shop-builttanks, especially the larger,
(01:00):
more valuable ones.
20,000 gallon size more often,more frequently.
So suddenly we're interactingwith this Standard Practice 031
a lot more than we ever have.
It is a tank repair standardthat covers repair modifications
to atmospheric shop fabricatedtanks made of carbon or
stainless steel and it isintended for tanks storing
flammable and combustibleliquids like the fuel that we
(01:22):
all store.
So I feel like there is a gap inour knowledge about this
standard, especially for owners,project managers, contracting
officers and other people whoare responsible for managing
capital expenditure orimprovement projects, and so I
have asked Joe Mentzer from STISPFA and Craig Fletcher from
Fletcher Consulting Inc to joinus today and answer some
(01:45):
questions that I have had aboutthe STI SP031 standard and then
hopefully also provide answersthat those of you that are in
that project managementcontracting officer role, so
maybe that you can understandthe parameters and how this is
used.
So, Joe, Craig, thank you forcoming on Tank Talk again, I
really appreciate having youhere.
I was hoping you couldintroduce yourselves, give us a
(02:05):
little bit about your backgroundand how you got into tanks
before we dig into STI SP031.
Joe Mentzer (02:11):
You can go first, Craig, this time.
Craig Fletcher (02:13):
My name is Craig Fletcher.
I'm the principal of FletcherConsultants.
We're a small Oakland,California-based firm that does
a lot of that provideenvironmental consulting
services of a wide variety.
Some of the services we provideinclude preparing SPCC plans,
conducting and performing SP001certified inspections, helping
companies that have large tankfleets whether they're national
(02:36):
laboratories or militaryinstallations, setting up
programs for that, as well asdoing other environmental
consulting things, includinghazardous waste facility
permitting and many otheraspects of the environmental
consulting world.
One with respect to mybackground, our firm's been
around since 2002.
Prior to that, I was aprincipal environmental engineer
(02:58):
with the Pacific Gas andElectric Company, where I worked
in the power generationindustry for a number of years.
During that time, I worked at apower plant where we had about
18 million gallons or so ofpetroleum storage on site, so I
got a little bit of experiencethere on the front lines with
that.
Prior to that, I was inenvironmental consulting at
another smaller facility andthen before then, I was in grad
(03:20):
school and before then I wasactually working for Chevron
Exploration Exploration Geology.
So that's a little bit about mybackground.
The part about getting intotanks and doing that.
Really I became an inspector in2009.
And we recognized at the time,with the changes in the SPCC
regulation, that we knew thattank inspection was going to be
(03:42):
an important part of not onlyunderstanding and preparing SPCC
plans, but also another avenuewhere we could learn more about
tanks.
That's when I first becamecertified as an inspector.
I've been doing it ever since.
Joe Mentzer (03:55):
My name is Joe Mentzer.
I'm the standards engineer forthe STI SPFA, which is the Steel
Tank Institute Steel PlateFabricators Association.
That's an organization that hasbeen around for many, many
years.
I've been here for about sixyears now.
Prior to that I was aconsultant.
I worked in most of the upperMidwest mostly Wisconsin but the
surrounding states and I helpedmy clients store and handle
(04:20):
regulated stuff certainlypetroleum, but other chemicals
worked in the printing industry,pharmaceutical industry, food
industry, automotive fluids allsorts of things.
I initially started off doingcleanups but one of my very
smart clients said actually he'dlike me to design systems so
they didn't leak.
And one thing led to anotherand I've been dealing with all
(04:41):
sorts of industry since then andjust decided to try something
different with STI.
I have been an SBO1 inspectorsince July 2001.
In fact, I think I attended thefirst class that ever certified
an inspector and, like I said,I've gotten involved in several
industries.
It's taken me some veryinteresting places.
I do have a degree inengineering.
I'm a mining engineer.
(05:01):
Went to Madison, Wisconsin.
Shannon Oelkers (05:04):
Is there like STI inspector numbers?
Are you like in the singledigits or something like that?
Joe Mentzer (05:09):
So the first series of numbers I am inspector 112
on the first list and theystarted with 100.
Yeah, the first class, I think,was 16 people.
Oh, it was for the state ofWisconsin An interesting story.
The state paid for the class.
There was a maximum number ofpeople, I think it was 20.
The guy who ran our stateprogram his name, was Sheldon
(05:31):
Shaw, a good, frugal Wisconsinguy.
There was three or four spacesopen and I was working with them
on some installations.
Hey, you want to come getcertified, just bring donuts.
So I got actually certified forthree boxes of donuts.
Shannon Oelkers (05:48):
Just bring donuts.
That's a deal it's paid for.
Joe Mentzer (05:50):
He didn't want the three or four spots extra to go
to waste, so he invited me.
Shannon Oelkers (05:54):
I wish my inspection had been three donuts
or three boxes of donuts.
Joe Mentzer (05:59):
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 thefirst batch of inspectors.
Shannon Oelkers (06:26):
Well, and I know you, gentlemen, because
I've taken classes from you, Joe, at both the API annual
conference, and then you andCraig together, were part of the
team that taught me when I gotmy STI certification, which is a
much higher number than 112back in 2022, I think but I
really appreciate you cominghere to talk about SP031.
So let's start off with whatthe history of the standard is.
When did it come into being andwhy was it created?
Joe Mentzer (06:35):
So SP031, I just kind of give you an idea of our
numbering sequence, the firsttwo numbers of the year.
So it was 2003, and it was thefirst standard produced that
year.
We produced SP-001 in 2000.
The original SP-001 reallyfollowed the API 653 standard,
which was inspection and repair.
(06:56):
But after they did theinspection standard it kind of
determined yeah, we got to havea repair standard as well.
Originally people wererepairing the shop-built tanks
to that API 653 standard.
The thing is there's some uniqueaspects to the construction of
shop-built tanks.
If you ever get a chance to seea tank shop, they're really,
(07:19):
really amazing at how they takesteel, roll it, form it, fit it,
line it up, weld it.
And I've been to shops wherethere's a pile of steel there
first thing in the morning andlate in the afternoon it's
sitting there in front of thepaint shop ready for a coat of
paint.
They do this very quickly butthere's some unique ways that
they assemble things that youhave to take into consideration
(07:39):
when you're making repairs.
And the Steel Tank Institute wesupport our products.
So we created this repairstandard.
We relied, we referenced backto the API standard on a regular
basis.
This is a good standard, butthere are some very specific
things in the SPO 31 standardabout what you can and cannot do
and how you address repairs incertain areas of the tank.
(08:02):
So it was needed.
So we produced it.
You address repairs in certainareas of the tank, so it was
needed so we produced it.
Shannon Oelkers (08:05):
So when you read through the standard, Joe
and Craig, it has some prettyspecific owner responsibilities.
Can we talk about what theowner is responsible for under
this standard?
Craig Fletcher (08:15):
Sure, Sure, I can talk about this one a little
bit, Joe.
I mean, essentially it's verysimilar to SP-001 in terms of
there's a lot of responsibilityon the owner.
After all, it's their asset,it's their equipment, right
Under the standard.
They're responsible for makingsure that they're following
federal, state and local codesand regulations.
(08:36):
They're making sure that peoplethat are working on the tank
system know what the hazards are, and oftentimes it's almost
universally, because tankrepairs generally are a
specialized field that requirescertain skills that are out
there.
They're going to need to reachout to specialists and, whether
that's an engineering firm or awelding company or a petroleum
(08:59):
contractor or whoever, that'swhere they're going to really
need to reach out for that.
So there's a lot more to itthan what I just described, but
realistically it's kind of ateam approach generally.
Joe Mentzer (09:10):
And bear in mind, with tank repair, the
preparation before is almostmore work than actually the
actual repair itself and theproper documentation, so that
the history and we're going todiscuss some things about
certifications and regulatoryobligations If you don't get
that right, it can just createheadaches.
(09:31):
So it's very important that theowner understands what they're
doing and make sure that he hasindividuals involved that
understand the process of doingit right.
Shannon Oelkers (09:41):
So understanding the process
overall and all the pieces of it, and then also making sure the
contractors you hire have aresume that indicate they're
specialists in this and havedone it successfully before.
This is not any handyman, anyguy that's turned a wrench.
You've got to find someonewho's specialized in it.
Joe Mentzer (09:57):
You're better off looking at people who repair
pressure vessels, the process orthe API 653 process, especially
in the organization.
The safety concerns thedocumentation afterwards.
Shannon Oelkers (10:12):
And for any tank repair, there's two pieces
to it.
One is cleaning and preparingthe tank for people to be able
to enter and fix it, and that'sa whole specific set of confined
space entry and how you cleanit and the waste stream that is
generated when you clean thetank and how you deal with the
waste.
And then there's the actualrepair and return to service.
And I believe this SP-031, itspecifically deals with the
(10:38):
repairs, not necessarily thetank cleaning.
That happens before correct.
Joe Mentzer (10:43):
Yeah, Tanks can be in all sorts of places One tank
sitting out by its lonesome inan area that's relatively easy
to isolate and clean.
When you're trying to fix themiddle tank in a 12 tank tank
farm, what about the other 11tanks surrounding it?
Or you're in a location that'sdoing all sorts of dangerous
things and they have a tank.
(11:05):
Sometimes you end up taking thetank, removing it, taking it
out of the location, doing therepair and putting it back in,
just because you know, and thenat that point maybe you're
better off just replacing thetank because you've done most of
the work.
I mean, it all depends on yourcircumstances, Although you are
correct, because I've seen morepeople call about repairing
(11:26):
complicated, larger tanksbecause of lead time to get it
and then just the cost overall.
Shannon Oelkers (11:33):
Lead time cost and then, just for Alaska
especially, the shipping costshave gone up so much to get a
20,000-gallon tank created inWashington at Greer and then
shipped all the way out toWestern Alaska.
It's significant, so theserepairs are starting to make
sense economically.
So I wanted to talk about howrepairs or modifications can
(11:53):
affect a tank listing orwarranty, because there's a big
warning at the beginning of 31that says this can impact your
listing or warranty.
What should owners be aware ofif they want to maintain their
tank listing and or a warranty,if it exists still?
Joe Mentzer (12:07):
So the tank listing part is tricky.
If you look in fire code itsays that the tank has to be
built for the purpose it'sintended to be used and
basically you have to providedocumentation satisfactory to
the authority havingjurisdiction that this tank's
going to work for what you'reusing it for, or Southwest
(12:33):
Research.
That works, but it's not theonly way.
That certification label getsinstalled at the time of
manufacture and the company thatbuilt the tank hires a
third-party listing agency thatinspects their operations,
inspects how they're buildingthings, doesn't inspect every
tank, but it keeps a good eye onhow the tanks are being built
and in following those rules,that manufacturer has then the
authority to add that listinglabel and that's put on at the
(12:56):
time the tank's built and theday that tank leaves the shop,
that tank is good to go.
Now what happens to it after itleaves the shop?
That's where things get tricky.
When you're dealing with tankrepairs, 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 thisrecognized industry standard and
(13:19):
these recognized, thesecertified individuals.
They're going to oversee thingsand at the end they're going to
write a document that says thistank's good to go and you got
to make sure your regulator'sgood with that.
In most cases you have the SPO31 standard and the API 653
standard.
Those are the standards used inthe industry and it has
certified people involvedholding their thumb in the air.
(13:42):
That's good enough to satisfythe authority having
jurisdiction.
Somebody qualified has saysthis tank is good to go.
Originally it's the listinglabel you have on the tank.
Now it's a qualified inspectorthat says between the listed
product that originally showedup and the modifications made
and all these steps followed,this tank is still good to
(14:04):
receive product.
So that's the listing part.
The warranty part's a whole lotmore tricky.
Because the warranty.
Warranties can come frommanufacturers or from
third-party warranty providers,but they're warranting the
product that the manufacturerproduces.
So either the manufacturer says, here you purchased my product,
(14:24):
I'm going to say for one year,you're good for material and
workmanship issues, or they canbuy a policy from a tank insurer
.
The Steel Tank Institute doesnot insure tanks.
There is an organization calledthe Steel Tank Insurance
Company that we do work with.
That does so.
We're different entities butthey're still only warranting
(14:45):
the original manufacturers.
The purchaser of the warranty isthe tank manufacturer and so if
you go start messing with thetank and changing things, well,
that isn't what the manufacturerbuilt, so that may not be
warranted.
I mean, I'm not going toguarantee you that it's going to
void the warranty, but I can'tguarantee you the warranty is
(15:06):
going to be there.
So you have to be reallycareful, you know.
And then why are you changingthis tank?
Are you repairing damage?
Did something else happen Again?
So yeah, most manufacturerwarranties are only one year.
The extended warranties that goon longer, that's very
difficult to establish.
I mean, if it's like adding aminor fitting and a problem
(15:26):
later didn't affect that fitting, the warranty may still cover
you.
But I can't guarantee anything.
I did talk to one warrantyprovider and that's what he told
me.
So yeah, you're kind of puttingthings at risk.
Shannon Oelkers (15:38):
So functionally if you're going to repair the
tank, if there's somehow awarranty in place.
Most of the times I've seenthis 31 applied.
The tank is well past that oneyear, but I did want to talk
about it a little.
Joe Mentzer (15:50):
If you have the original manufacturer make the
change, then you still might bein good shape.
Shannon Oelkers (15:57):
Let's ship it all the way back to Lakewood.
Joe Mentzer (16:00):
Well, maybe it's more down here in the
Continental, but there are sometank manufacturers that have
service departments.
Shannon Oelkers (16:07):
Oh, that will come and actually do it.
Joe Mentzer (16:09):
They not only build the tank, install the tank,
they service the tank.
That's good to know, andoccasionally we do have a case
where somebody ships a tank,buys a tank, ships it and all of
a sudden we came up one fittingshort.
Can you please come and installone more fitting?
And some guys will, some won't.
Shannon Oelkers (16:29):
Okay.
So, Craig, how does that playinto the SPCC?
If you're going to have a tankrepaired under 031, do we need
to alter the SPCC at the sametime?
Or update amend.
Craig Fletcher (16:41):
Yeah, I think that has to depend on what the
scope of the actual repair ormodification is.
Is it's really kind of the partthat you can sort of get into
that world of?
Does it have a material impacton the ability of the facility
to discharge from the property?
It's probably a site specificthing based on what they're
actually intending to do.
(17:02):
Just one last thing about thelisting issue is that you know,
in current practice.
In current tank installationpractice, virtually every tank
that's going to be installednowadays of the shop fabricated
design is going to typicallyhave some kind of listing
afforded to it, whether aCUL-142 or Southwest Research.
(17:23):
We don't normally see peopleputting in custom specialized
tanks that have to go throughsome really elaborate design
review by the fire department todetermine whether they're
suitable.
That's just not really apractical thing, right?
But if you are going to go inand do something like welding on
a UL listed tank or cut a newhole in the top for another
fitting, you're definitely goingto be affecting the listing
(17:46):
status of that tank.
So in California and otherjurisdictions where that listing
is so important to firemarshals, that can really affect
your ability to what may workin that situation.
However, that's going to varyby your local jurisdiction.
So in some cases you know itmay be something completely
different.
Your mileage may vary put itthat way with your local
(18:08):
jurisdiction.
Shannon Oelkers (18:10):
So maybe a good catch-all, if somebody's
sitting in the projectmanagement seat, is that they
should let their SPCC writerknow that they're modifying the
tank so that, if it applies,they are not leaving it out of
an SPCC amendment if it'srequired.
Craig Fletcher (18:24):
Definitely.
Shannon Oelkers (18:25):
Okay, so we had this question come up actually
just a month or two ago.
Can you still use SP31 if youdon't know the original
construction details for yourtank, like the labels?
It's fallen off or is illegible?
We're not really sure if it wasa UL-142, but we're assuming.
Can you still apply the 031?
Joe Mentzer (18:46):
You know the standard kind of addresses that
you have to look, you get backto that listing issue.
If you don't know theconstruction standard, how is
the tank listed?
And also what's the tankholding and are you required to
have?
So it doesn't prevent you fromusing it, but I guess in the
circumstance that you're usingthe tank you have to know that
it's suitable for the purposethat it's being used for.
(19:09):
Also, you have to have thatdiscussion with the authority
having jurisdiction.
If you told the authorityhaving jurisdiction I don't know
what the listing is on thistank but I want to change it
he's probably going to go to the.
Well, you don't know thelisting on this tank, then why
are you using it in the firstplace?
So it gets a little tricky,
It's Alaska so we use whatevertanks we can find.
(19:30):
Yeah, the standard says you can, as long as you
understand the construction ofthe tank and you take the proper
steps.
But we go back to that thingCraig talked about.
The owner's got to make surethat the tank is suitable for
use, and that also even goesback to the SBO.
It's up to the owner to makesure things are suitable for use
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Joe Mentzer (20:36):
Now I will tell you I have seen a lot of unlisted
tanks used for storing thingsthat aren't regular, like
asphalt cement, because it's nota liquid.
And you look at them andthey're really UL tanks.
And that's because the ULstandard is a good shop
fabrication standard.
It works well in a shop.
So does the API 12 series.
Other industries just use itbecause it's a recognized
standard.
(20:56):
They just don't pay the extramoney to buy the UL label.
Shannon Oelkers (21:00):
We do see that sometimes where it was
constructed for some otherpurpose, but now they're using
it for fuel.
Joe Mentzer (21:06):
Yeah, I've also seen some tanks built in like
South America, where some veryskilled metal workers collected
a bunch of scrap steel and putsomething together.
It's like, oh, that's not evenyou know.
Great work, guys, but not evenclose.
Craig Fletcher (21:21):
And, getting back to your example, I would
think too that you are going tohave tanks that are not have a
listing right.
We talked about API 12F or API650, appendix J.
Those are not true listings butthey are recognized standards.
So that is definitely allowedand it is very common to go out
to older facilities inparticular where you almost have
(21:43):
to make some kind of assumptionbased on your best examination.
Was it built to a shopfabricated standard?
Probably.
Which was it?
Well, I did some steelthickness testing on it and I
know by the design this isprobably following a UL standard
, but I can't say for certain.
But I think those are kind ofwhere a certified inspector or
(22:04):
other knowledgeable party may behelpful in guiding that.
You know the use of that.
But I think SP-031 certainlyallows discretion for owners to
be able to use that in thoseconditions where it's not.
Joe Mentzer (22:16):
You got to keep the regulator happy.
Shannon Oelkers (22:19):
So what I'm hearing is, if you have a tank
and you're uncertain of itsconstruction standard, either
due to age or loss of recordkeeping, it may be wise to
include a certified STI or APIinspector on the team that's
helping you with this capitalimprovement project, and or a
mechanical or structuralengineer that's familiar with
this product, the type of useand the fire codes, to be able
(22:41):
to give the blessing from theengineering side of things
rather than just relying onassumptions.
Okay, that sounds good.
I think those are good,actionable steps to take.
If you've got a tank, you'renot sure of its history, then
you can just add those to theteam.
I was wondering if you guyscould go over some common
repairs or modifications that dooccur in shot belt tanks,
(23:01):
because I do think thatsometimes the standard is
brought in and maybe I don'tknow like.
I'm just curious, like what arethe most common versions of
repairs and modifications thatoccur under it?
Craig Fletcher (23:13):
It's not particularly common, at least
here in California, because manytimes it's maybe more cost
effective to simply replace thetank.
But I can tell you in othercases it ranges a gamut from
something as simple as welddeposition, like puddle welding
to fill in.
If we're doing an internalinspection, we have corrosion
pits.
That's pretty common.
(23:33):
If we have gone into a tank orwe've seen reworking substandard
welds or cracking areas ofcracking those are pretty common
.
Or if you do have areas whereyou have corrosion or damage to
the tank, replacing certainsections using either patch
plates or insert plates,patching over it or inserting a
new piece of steel to match thecurvature there.
(23:55):
So I would say those are someof the most common ones that you
would probably encounter out inthe field Particularly.
I'm just trying to think alittle bit about some of the
challenges you face in Alaskaand what the genesis of these
repairs are.
But I would suspect some ofthose have to do with corrosion
and that or that's probably themost common one there, I would
think.
But I don't know.
(24:15):
Joe, you got anything to add tothat?
Joe Mentzer (24:17):
Well, in the Midwest the issue is bottom
replacement on verticalcylindrical tanks, and that's
because people let the leavesand junk build up in the bottom
of their dikes and let them holdmoisture in the bottom inch or
two or just all beat up, rottenaway.
(24:38):
So that's not an uncommonrepair.
Occasionally get some localizedcorrosion on the shell for
whatever reason.
Usually again it's somethingwet, got up against the side of
it and they ignored it for toolong.
And, yes, they put a patchplate over the top and make sure
that it's sealed up to theoriginal tank.
The original tank hasn't failed, but it's just got a thin spot.
So, yeah, those are the commonrepairs.
Occasionally I've done someinsert patches again due to
(25:00):
really just poor housekeeping onthe outside, on the inside
that's where the bottomreplacement comes in.
And then occasionally adding anew fitting on top of the tank.
Change in service, change inoperation we need another
fitting.
But again and Craig hit thepoint too often Occasionally,
adding a new fitting on top ofthe tank Change in service,
change in operation, we needanother fitting.
But again and Craig hit thepoint too often, once you've got
the tank cleaned and ready togo, yeah, well, you know,
(25:21):
instead of adding this newfitting, 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 (25:25):
Yeah, some of the ones we've seen lately.
I've seen a couple of steelsaddle support repairs where the
steel supports were corrodingand failing to support the tank.
There was some buckling.
And we've also seen themremoving bottom appurtenances
and moving them to the top.
Like the tank was older and ithas a water draw on the bottom,
but they maybe want to use itfor aviation, so they remove
(25:47):
that, patch it up and then movesomething to the top rather than
having it extrude from thebottom and then, of course, the
corrosion patches.
That's the number one reasonthat we get 31.
That's usually why the tankcannot continue in service
without a repair, and that'swhat's driving the use of this
31 is that they can't afford toreplace it.
Patching it is probably cheaper, or they've determined it to be
(26:07):
cheaper and they move on.
I also had a note here.
Are there any modificationsthat are not covered by 31?
And if there are, why aren'tthey covered?
Craig Fletcher (26:16):
So there are some provisions under Go ahead,
Joe, as I say there really is.
Joe Mentzer (26:21):
Sbo 31 says here's the repairs you can make and
here's the modifications you canmake.
So you got to be careful.
You can't, and you also have tohave some recognition of the
original tank listing as well.
You know things like increasingthe size of the tank that's not
covered under this standard,turning a horizontal tank into a
vertical tank Again, thatwasn't how it was designed to be
(26:43):
.
There's things that an engineercan do.
The term is called aconvertisontal and Craig taught
you that one Convertisontal.
Shannon Oelkers (26:50):
I have photos of a few of those that I have
encountered't go redesigning thetank or, you know, changing its
(27:13):
original intent significantlyin a repair.
Joe Mentzer (27:17):
That's where you maybe need a new, probably need
a new tank.
At that point you're probablybetter off just buying a new
tank.
Or you need an engineer andthen there's certain damage that
we can't account for in repair.
You know the tank I get thistent.
My tank's been in a fire, it'sbeen baked, great it's done.
Nobody, nobody's going to saythat tank's good to go.
(27:39):
Your insurance is probably goingto cover it.
Yeah, yeah.
Or what's the other one?
Guy had a tank in a undergroundvault.
The vault filled with water.
The tank floated, bent water.
The tank floated bent all ofthe fittings over on top.
Just you know how can I fix it?
You can't, don't even wasteyour time.
So yeah, there are absolutelylimitations.
Craig Fletcher (27:59):
So I would say too, Shannon, and some of that
within the specific portions ofit.
There's other examples wherethings where you're going to
need engineering assistance,You're going to kind of step
outside of the scope of SP-031for at least parts of it, If
you're designing a new anchoragesystem for a tank like you're
going to put new anchor chairson a tank or doing it, you're
(28:19):
going to have to have someengineer involved to help you
with the structural aspects ofit.
If you have pipe penetrationsthat are greater than 12 inches
below the liquid level, now youhave to start thinking about
what are we going to do toreinforce that location and at
that point then again you'reback into some more of the
engineering side of it as well.
(28:39):
So, changing the height of atank, adding another course to
the top of the tank, that's notcovered under the
run-of-the-mill SP-031 standard.
It can be done, but it's goingto be outside the scope of the
standard.
So I think and Joe can speak tothis but I think most of what
SP-031 is for is to reallyaddress the common repairs and
(28:59):
alterations you might have atank, give the owner and the
industry guidance on what can bedone and what's not allowed to
be done, including restrictionson where you can do certain
welds or repairs.
But it certainly can't accountfor every possible thing that's
out there, particularly formajor modifications for tanks.
Yeah, Okay.
Shannon Oelkers (29:19):
So if you're sitting in that project
management chair, it's good tobe aware that there are limits
to what can be handled under the31 standard and if you need to
go outside of them, that's fine.
But you've got to have somekind of engineering presence to
guide that and to make sure thatthe contractors are meeting all
of the different engineeringstandards and fire code
requirements and regulatoryrequirements that go with those
(29:41):
major repairs or revisions.
And the 31 is limited to somevery specific ones and you
should know which ones they are.
If you're going to be modifyinga tank Okay Right, that sounds
good.
Related to that, tank repairsrequire multiple types of
qualified personnel.
I was wondering if you guyscould review what kind of
contractor qualifications mightbe needed to perform the repairs
(30:02):
and the inspections, becausethe SPI, sc-31, it talks about
what you need to have for repairand then what you need to have
to qualify for inspection.
Could you guys address thosetwo pieces?
Joe Mentzer (30:13):
You need an SP001 inspector because they have to
inspect the tank and one of theimportant things is make sure
you thoroughly inspect the tankbefore you perform a repair,
because the last thing you'regoing to do is fix this one
little spot over here and ohwait a minute, you got this huge
problem over here.
Any welding done, you have touse a certified welder, so make
sure that that welder isqualified.
(30:34):
You may have to do somenon-destructive testing after
the repair is made and,depending upon the testing, you
got to make sure that the persondoing the testing is qualified
to do that testing.
And then you may have to testthe integrity of the tank.
I don't think there's anyparticular qualification to do
an integrity test, but make surethe person knows what they're
doing, because otherwise theycan do more damage.
(30:56):
We've seen that happen a fewtimes.
The problem is each repair canbe a little bit different, so
that the people involved mayneed to be a little bit
different.
But these are kind of specificskills.
You know, I've seen lots oftanks.
Oh, you know this beautifulfour-inch perfectly square patch
on the end of a tank welded inwonderfully yeah, that's great.
(31:18):
Minimum patch is six inches,supposed to round the corners.
That's the sort of thing yousee when people don't understand
the standards involved in them.
Craig Fletcher (31:27):
I'd also add one thing to that too, shannon,
that you know, under thestandard for people that can
qualify to do repairs, that alsoincludes welding personnel at a
facility that actuallymanufactures STI, API, ul or
Southwest Research Tank.
So those fabricators, althoughthey're not explicitly certified
(31:48):
welders like we think underASME or other things, they are
also qualified under thestandard to make those repairs.
So there's some specificlanguage in the standard who can
do what?
So you definitely want tofollow that, particularly if
you're maybe a contractingofficer or someone else trying
to put together a spec packageor a bid package for someone,
(32:09):
making sure they know who thequalifications are, because you
wouldn't want to go through thiswhole process and have someone
who's not qualified, right?
No, similarly, the inspectionscan be done, like Joe mentioned,
from an STI certified inspector.
Inspections can be done, likeJoe mentioned, from an STI
certified inspector.
It can also be a API 653inspector or it can be a person
who's employed by a manufacturerof people that make STI or API
(32:32):
or UL tanks or SouthwestResearch tanks.
So there's a little bit more ofplay in there, designed for
because I know in my experiencetrying to get sometimes back to
the fabricator.
If you can to help you can be agood approach if they've
already perhaps built the thing.
Having said that, your mileageis going to be different up in
Alaska, where you're at remotelocations where you won't have
(32:55):
that luxury.
Shannon Oelkers (32:56):
So that's kind of the other basis it's good to
cover, though, because we have apretty significant listenership
in the state of Washington andthe state of Oregon as well, and
they can absolutely interactwith their manufacturers.
They're present All right.
So if contractors are followingSP 31, they should be providing
a final report or record of allthe modification, repairs and
testing that occurred.
(33:17):
I personally can attest to awide interpretation of what this
report should look like andinclude.
Could you maybe review what afinal report should look like?
I'm hoping that thesecontracting officers and project
managers and owners could beset up to expect a certain
quality or a certain what theyneed to get back in that report
to show regulators and the SPCCplan writer that the repairs
(33:42):
occurred, because I have seeneverything from a one-page
checklist that's hand-filled outwith a mechanical pencil to a
proper report with lots ofsupporting documents.
So maybe let's go over what aproper report would look like.
Craig Fletcher (33:53):
I can talk a little bit about that one.
And basically, getting back tothe contracting officer or
someone trying to set up aspecification, the standard
itself has some specificrequirements.
It says that it has to showthat the repair or modification
that was done was doneappropriately.
The testing and remember, foreach type of repair or
modification you're going to do,there is an inspection and some
(34:17):
type of testing required forthat.
It's going to vary based onwhat the scope of the repair is.
Some may be just a simplevisual inspection, some may be
more involved.
So this is all covered withinthe standard.
So I would think that if I wasa contracting officer having
access to what the standardexplicitly says, if I'm trying
to set that up, I woulddefinitely include that.
(34:38):
There's also a discussion of howin SP-031 talking about is the
design and meeting the standardand code compliance after the
repair or modification was doneand there should be at least
some overview of what was somedescription of what the repair
or modification was done.
That seems prettystraightforward and there's
(34:59):
documentation that's completewith that.
So we do see this on the 653side where they have.
There's similar requirementsthere.
But Appendix B of SP-031 has afinal inspection form in the
back there that can help guidethat documentation 001
(35:24):
inspection.
Typically, what we want toinclude in a report like that is
a summary of what was done,what testing was done, what
repairs were done, the testreports, whether they passed or
failed or what the results of itwere, sketches of the area that
was repaired or modified andphotographs of what the work and
any other materials.
You may include thequalifications of your welders
or you may include other thingsof that nature that apply to the
(35:46):
actual modification or repairthat's done.
But it's a very important stepand as an owner, you clearly
want that.
You definitely want that inyour back pocket for your own
protection, because if you havehad repairs done, I would expect
that someone at a regulatoryagency may request that, because
they'll probably look at yourtank files as part of the SBCC
(36:07):
plan inspections.
So that's kind of what I wouldcertainly say.
Joe Mentzer (36:12):
You've hit one of the important points.
At some point, some qualifiedindividual is going to look at
this tank and say, hey, whathappened here?
I have my list and my list saysyou know one is there should be
some summary or finding on theoriginal.
Why are you doing this repair?
Maybe it's back to a tankinspection report where problems
were listed, or you know therequest that I needed out of
(36:32):
fittings for some reason.
But why is the repair done?
Certainly, documenting theoriginal tank construction
standard, whether you'vedocumented it or this is what
you believe.
But that AST record, theoriginal one's good and you may
need an updated record dependingupon what changes are made.
Certainly you know a summary ofeverything done by the repair
(36:53):
firm at this time.
So that way, in 20 years, whensomeone does the next formal
inspection, why is this patchhere?
Oh, okay, here it wasdocumented.
You know, again, got to throwsome crumbs out for the next
inspector who's going to betrying to figure out what you're
doing.
Certainly, yes, thecertifications for people
involved, the results of anytesting, depending upon the
(37:14):
level of testing.
If you do an integrity test,that record should be kept.
Certainly, if you've done sometesting, you want credit for it.
And then finally, if theauthority having jurisdiction,
like Craig, said they may beinterested, they may need to
come and reinspect the tankbefore 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 patchon the tank.
Shannon Oelkers (37:35):
Or more.
So keeping it for the life ofthe tank is important as well.
Like this is a document thatcannot be forgotten or left in
an email.
It absolutely has to beincluded in the file for that
specific tank once it occurs.
Joe Mentzer (37:47):
I learned from my predecessor it's good to leave
notes.
She left me some things andthings.
Oh yeah, that makes sense now.
So leave the next individualsome information to help them do
their job.
Shannon Oelkers (38:00):
I think with the STI standard, what does make
it a little more difficult isthat you've got 20-year
inspection intervals for a classone tank and in 20 years you
can have multiple turnovers in ajob, and so we definitely focus
on keeping it for the life ofthe tank, keeping it hard copy
where the tank lives, not justin digital land but in multiple
places, and then our firm, ofcourse, keeps records forever so
(38:23):
you can go back to us even ifyou didn't keep it internally,
which has happened sometimes.
So we've talked a lot aboutwriting bid packets or
specification packets.
Do you guys have any pro tipson how to write this standard
into a proposal or an RFP or aspec package to make sure that
when you send it out, the bidsyou're getting back are going to
be compliant with this standard?
Craig Fletcher (38:44):
I think on that.
Shannon, you're going to haveto have somebody on the owner's
side have access to SP031,because that's really that's
your guideposts on what you arerequired to do.
It's not available anywhereelse.
I mean it's going to comestraight out of that standard.
So having that is certainly one, and trying to incorporate to
(39:04):
the extent you can in that bidrequest the specific items that
people have to do when they aredoing repairs and modifications
to tanks.
The other part of it too is thatand I don't know, I'm sure it
depends on the actual bidprocess or spec you're preparing
is that it's not particularlycommon to have the petroleum
(39:26):
contractor or the repair companybe the same as the inspection
company.
So in that case there is abenefit to having some
separation there.
That's another consideration,because there could be some
conflict of interest issues withthat.
So that may be something forprocurement officers to think a
little bit about how we're goingto get this work package
(39:48):
together, who's going to do whatand who's going to retain the
individual parties for that.
So in my experience, relyingsolely on a contractor to do
everything, when we actually andyou know this as a plan writer
is that we need something thatwe can hang our hat on to go
with our SPCC plan, which is aregulatory compliance document.
(40:08):
So that's where we want to endup at the end of the day, to be
able to have that.
So that's kind of what I wouldthink might be something
worthwhile for those who want todo bid requests for something
like this to keep in mind.
Joe Mentzer (40:19):
There are some firms that do regular repair on
tanks or industrial stuff andunderstand what they're getting
into, and it's certainly it'sgood that the person that you're
contracting understands whatthey're getting into.
Getting them to come and have alook at the tank is always
important.
Making sure they understand therules that are in play at the
(40:41):
facility, depending upon the.
You know, if you're workingdeep in the heart of an
industrial facility, they canhave some pretty significant
rules on what you can and cannotdo.
It increases their time andtheir effort, so you got to make
sure they understand thecircumstances associated with it
.
And making sure they understandthe hazards associated with
(41:01):
either the materials they'reworking around or materials
they're working with isimportant as well.
Shannon Oelkers (41:06):
So providing a good, clear description of the
facility, the products they'reworking with and the general
environment.
Making sure that you're listingout the qualifications needed
for the actual repair andmaintenance, separating the
inspection from that to avoidconflict of interest.
Spending the couple hundreddollars to actually buy the SP31
standard and reading it priorto starting the project.
(41:27):
And then I think I would add,making a nice clean list of
deliverables and say finalreport, including photo log,
including report data, includingnon-destructive testing results
in PDF or something like that,so that it's all together.
It's not 27 emails of 27documents which we have
definitely gotten before.
(41:47):
So assembling it into that kindof a final report, okay, those
are all really good tips.
I agree with you that justpurchasing the SP-31, it is not
that long, it is not thatcomplicated, but you do need to
have it if you're going to bedoing repairs to a tank at your
facility.
Okay, so I think that'severything I have for SP-31.
Does STI SPFA have anyadditional resources for our
(42:09):
listeners if they want to learnmore about this standard, sti
SP-31?
Joe Mentzer (42:14):
Actually, on August 11th we're doing a webinar on
SP-031 and more so on thingspeople do wrong with it, so that
one is coming.
We've done that.
One did that out for the Coupafolks in California did it down
at the National Institute ofStorage Tank Maintenance
recently.
We're going to do that as awebinar coming and our website
(42:37):
does have the Frequently AskedQuestions section, which does
address some things.
That's certainly a good placeto look.
The whole STISPFAorg website isa great place for information
on storage tanks how to properlymaintain them, how to properly
operate, how to properly repairthem.
So yeah, there is someinformation available and
talking to a qualified inspectorcertainly helps.
(42:59):
They should understand that theAPI guys, the STI guys it's
similar repairs.
Shannon Oelkers (43:06):
Great.
Thank you both so much fortaking the time today to go
through that standard with us.
Like I said, we're just seeingit used so much more.
I'm definitely going to tune infor that August webinar because
I think it does help to knowwhat to avoid and to be aware,
and so I would encourage all ofmy listeners.
And then to clarify we'rerecording this in 2025.
So that'll be live August 11thof 2025.
Joe Mentzer (43:27):
10 am Central Time.
Shannon Oelkers (43:28):
Ooh, 10 am Central Time, which would be
what 6 am 7 am Alaska Time.
I thank you both so much forcoming on.
I really appreciate it.
Do you have any final wordsbefore we log off for today?
Craig Fletcher (43:40):
No, we're always happy to answer questions off
for today, no we're always happyto answer questions, so if
anybody has anything, Iappreciate it.
Thanks for having us.
Awesome, yeah, thank you forhaving us.
Shannon Oelkers (43:47):
Thank you both for coming.
I just appreciate having bothof your expertise.
It truly was a pleasure andjust wonderful to hear all this
stuff and learn.
I appreciate it so much.
Joe Mentzer (43:57):
Thanks, happy to help.
Shannon Oelkers (44:01):
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 tomake sure that you knew the
following this podcast is forinformational purposes only and
should not be considered legalor regulatory advice.
We are not responsible for anylosses, damages or liabilities
that may arise from the use ofthis podcast.
(44:22):
This podcast is not intended toreplace professional regulatory
or legal advice, and the viewsexpressed in this podcast may
not be those of the host thatwould be me or Integrity
Environmental.
Thank you very much forlistening and if you do need
professional regulatory advice,we'd be happy to help you as
part of our consulting services.
Welcome to Tank Talk with Integrity Environmental.
Join us as we sit down withfounder, principal consultant
and bulk fuel storage expert,Shannon Oelkers, to explore
regulations, safety andessential tips for navigating
the bulk fuel storage industry.
Join us as we explore theunique joys of work and life in
Alaska with industry experts,including our team, vendors we
(00:30):
work with and the companies wesupport.
Shannon Oelkers (00:36):
Hi, welcome to Tank Talk.
This is Shannon Oelkers, andtoday we're going to be talking
about the Steel Tank InstituteStandard Practice 031.
And there's a very specificreason for that.
With soaring steel prices andespecially in Alaska, where
logistics can be a big part ofthe cost of a tank, we're seeing
repair to damaged shop-builttanks, especially the larger,
(01:00):
more valuable ones.
20,000 gallon size more often,more frequently.
So suddenly we're interactingwith this Standard Practice 031
a lot more than we ever have.
It is a tank repair standardthat covers repair modifications
to atmospheric shop fabricatedtanks made of carbon or
stainless steel and it isintended for tanks storing
flammable and combustibleliquids like the fuel that we
(01:22):
all store.
So I feel like there is a gap inour knowledge about this
standard, especially for owners,project managers, contracting
officers and other people whoare responsible for managing
capital expenditure orimprovement projects, and so I
have asked Joe Mentzer from STISPFA and Craig Fletcher from
Fletcher Consulting Inc to joinus today and answer some
(01:45):
questions that I have had aboutthe STI SP031 standard and then
hopefully also provide answersthat those of you that are in
that project managementcontracting officer role, so
maybe that you can understandthe parameters and how this is
used.
So, Joe, Craig, thank you forcoming on Tank Talk again, I
really appreciate having youhere.
I was hoping you couldintroduce yourselves, give us a
(02:05):
little bit about your backgroundand how you got into tanks
before we dig into STI SP031.
Joe Mentzer (02:11):
You can go first, Craig, this time.
Craig Fletcher (02:13):
My name is Craig Fletcher.
I'm the principal of FletcherConsultants.
We're a small Oakland,California-based firm that does
a lot of that provideenvironmental consulting
services of a wide variety.
Some of the services we provideinclude preparing SPCC plans,
conducting and performing SP001certified inspections, helping
companies that have large tankfleets whether they're national
(02:36):
laboratories or militaryinstallations, setting up
programs for that, as well asdoing other environmental
consulting things, includinghazardous waste facility
permitting and many otheraspects of the environmental
consulting world.
One with respect to mybackground, our firm's been
around since 2002.
Prior to that, I was aprincipal environmental engineer
(02:58):
with the Pacific Gas andElectric Company, where I worked
in the power generationindustry for a number of years.
During that time, I worked at apower plant where we had about
18 million gallons or so ofpetroleum storage on site, so I
got a little bit of experiencethere on the front lines with
that.
Prior to that, I was inenvironmental consulting at
another smaller facility andthen before then, I was in grad
(03:20):
school and before then I wasactually working for Chevron
Exploration Exploration Geology.
So that's a little bit about mybackground.
The part about getting intotanks and doing that.
Really I became an inspector in2009.
And we recognized at the time,with the changes in the SPCC
regulation, that we knew thattank inspection was going to be
(03:42):
an important part of not onlyunderstanding and preparing SPCC
plans, but also another avenuewhere we could learn more about
tanks.
That's when I first becamecertified as an inspector.
I've been doing it ever since.
Joe Mentzer (03:55):
My name is Joe Mentzer.
I'm the standards engineer forthe STI SPFA, which is the Steel
Tank Institute Steel PlateFabricators Association.
That's an organization that hasbeen around for many, many
years.
I've been here for about sixyears now.
Prior to that I was aconsultant.
I worked in most of the upperMidwest mostly Wisconsin but the
surrounding states and I helpedmy clients store and handle
(04:20):
regulated stuff certainlypetroleum, but other chemicals
worked in the printing industry,pharmaceutical industry, food
industry, automotive fluids allsorts of things.
I initially started off doingcleanups but one of my very
smart clients said actually he'dlike me to design systems so
they didn't leak.
And one thing led to anotherand I've been dealing with all
(04:41):
sorts of industry since then andjust decided to try something
different with STI.
I have been an SBO1 inspectorsince July 2001.
In fact, I think I attended thefirst class that ever certified
an inspector and, like I said,I've gotten involved in several
industries.
It's taken me some veryinteresting places.
I do have a degree inengineering.
I'm a mining engineer.
(05:01):
Went to Madison, Wisconsin.
Shannon Oelkers (05:04):
Is there like STI inspector numbers?
Are you like in the singledigits or something like that?
Joe Mentzer (05:09):
So the first series of numbers I am inspector 112
on the first list and theystarted with 100.
Yeah, the first class, I think,was 16 people.
Oh, it was for the state ofWisconsin An interesting story.
The state paid for the class.
There was a maximum number ofpeople, I think it was 20.
The guy who ran our stateprogram his name, was Sheldon
(05:31):
Shaw, a good, frugal Wisconsinguy.
There was three or four spacesopen and I was working with them
on some installations.
Hey, you want to come getcertified, just bring donuts.
So I got actually certified forthree boxes of donuts.
Shannon Oelkers (05:48):
Just bring donuts.
That's a deal it's paid for.
Joe Mentzer (05:50):
He didn't want the three or four spots extra to go
to waste, so he invited me.
Shannon Oelkers (05:54):
I wish my inspection had been three donuts
or three boxes of donuts.
Joe Mentzer (05:59):
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 thefirst batch of inspectors.
Shannon Oelkers (06:26):
Well, and I know you, gentlemen, because
I've taken classes from you, Joe, at both the API annual
conference, and then you andCraig together, were part of the
team that taught me when I gotmy STI certification, which is a
much higher number than 112back in 2022, I think but I
really appreciate you cominghere to talk about SP031.
So let's start off with whatthe history of the standard is.
When did it come into being andwhy was it created?
Joe Mentzer (06:35):
So SP031, I just kind of give you an idea of our
numbering sequence, the firsttwo numbers of the year.
So it was 2003, and it was thefirst standard produced that
year.
We produced SP-001 in 2000.
The original SP-001 reallyfollowed the API 653 standard,
which was inspection and repair.
(06:56):
But after they did theinspection standard it kind of
determined yeah, we got to havea repair standard as well.
Originally people wererepairing the shop-built tanks
to that API 653 standard.
The thing is there's some uniqueaspects to the construction of
shop-built tanks.
If you ever get a chance to seea tank shop, they're really,
(07:19):
really amazing at how they takesteel, roll it, form it, fit it,
line it up, weld it.
And I've been to shops wherethere's a pile of steel there
first thing in the morning andlate in the afternoon it's
sitting there in front of thepaint shop ready for a coat of
paint.
They do this very quickly butthere's some unique ways that
they assemble things that youhave to take into consideration
(07:39):
when you're making repairs.
And the Steel Tank Institute wesupport our products.
So we created this repairstandard.
We relied, we referenced backto the API standard on a regular
basis.
This is a good standard, butthere are some very specific
things in the SPO 31 standardabout what you can and cannot do
and how you address repairs incertain areas of the tank.
(08:02):
So it was needed.
So we produced it.
You address repairs in certainareas of the tank, so it was
needed so we produced it.
Shannon Oelkers (08:05):
So when you read through the standard, Joe
and Craig, it has some prettyspecific owner responsibilities.
Can we talk about what theowner is responsible for under
this standard?
Craig Fletcher (08:15):
Sure, Sure, I can talk about this one a little
bit, Joe.
I mean, essentially it's verysimilar to SP-001 in terms of
there's a lot of responsibilityon the owner.
After all, it's their asset,it's their equipment, right
Under the standard.
They're responsible for makingsure that they're following
federal, state and local codesand regulations.
(08:36):
They're making sure that peoplethat are working on the tank
system know what the hazards are, and oftentimes it's almost
universally, because tankrepairs generally are a
specialized field that requirescertain skills that are out
there.
They're going to need to reachout to specialists and, whether
that's an engineering firm or awelding company or a petroleum
(08:59):
contractor or whoever, that'swhere they're going to really
need to reach out for that.
So there's a lot more to itthan what I just described, but
realistically it's kind of ateam approach generally.
Joe Mentzer (09:10):
And bear in mind, with tank repair, the
preparation before is almostmore work than actually the
actual repair itself and theproper documentation, so that
the history and we're going todiscuss some things about
certifications and regulatoryobligations If you don't get
that right, it can just createheadaches.
(09:31):
So it's very important that theowner understands what they're
doing and make sure that he hasindividuals involved that
understand the process of doingit right.
Shannon Oelkers (09:41):
So understanding the process
overall and all the pieces of it, and then also making sure the
contractors you hire have aresume that indicate they're
specialists in this and havedone it successfully before.
This is not any handyman, anyguy that's turned a wrench.
You've got to find someonewho's specialized in it.
Joe Mentzer (09:57):
You're better off looking at people who repair
pressure vessels, the process orthe API 653 process, especially
in the organization.
The safety concerns thedocumentation afterwards.
Shannon Oelkers (10:12):
And for any tank repair, there's two pieces
to it.
One is cleaning and preparingthe tank for people to be able
to enter and fix it, and that'sa whole specific set of confined
space entry and how you cleanit and the waste stream that is
generated when you clean thetank and how you deal with the
waste.
And then there's the actualrepair and return to service.
And I believe this SP-031, itspecifically deals with the
(10:38):
repairs, not necessarily thetank cleaning.
That happens before correct.
Joe Mentzer (10:43):
Yeah, Tanks can be in all sorts of places One tank
sitting out by its lonesome inan area that's relatively easy
to isolate and clean.
When you're trying to fix themiddle tank in a 12 tank tank
farm, what about the other 11tanks surrounding it?
Or you're in a location that'sdoing all sorts of dangerous
things and they have a tank.
(11:05):
Sometimes you end up taking thetank, removing it, taking it
out of the location, doing therepair and putting it back in,
just because you know, and thenat that point maybe you're
better off just replacing thetank because you've done most of
the work.
I mean, it all depends on yourcircumstances, Although you are
correct, because I've seen morepeople call about repairing
(11:26):
complicated, larger tanksbecause of lead time to get it
and then just the cost overall.
Shannon Oelkers (11:33):
Lead time cost and then, just for Alaska
especially, the shipping costshave gone up so much to get a
20,000-gallon tank created inWashington at Greer and then
shipped all the way out toWestern Alaska.
It's significant, so theserepairs are starting to make
sense economically.
So I wanted to talk about howrepairs or modifications can
(11:53):
affect a tank listing orwarranty, because there's a big
warning at the beginning of 31that says this can impact your
listing or warranty.
What should owners be aware ofif they want to maintain their
tank listing and or a warranty,if it exists still?
Joe Mentzer (12:07):
So the tank listing part is tricky.
If you look in fire code itsays that the tank has to be
built for the purpose it'sintended to be used and
basically you have to providedocumentation satisfactory to
the authority havingjurisdiction that this tank's
going to work for what you'reusing it for, or Southwest
(12:33):
Research.
That works, but it's not theonly way.
That certification label getsinstalled at the time of
manufacture and the company thatbuilt the tank hires a
third-party listing agency thatinspects their operations,
inspects how they're buildingthings, doesn't inspect every
tank, but it keeps a good eye onhow the tanks are being built
and in following those rules,that manufacturer has then the
authority to add that listinglabel and that's put on at the
(12:56):
time the tank's built and theday that tank leaves the shop,
that tank is good to go.
Now what happens to it after itleaves the shop?
That's where things get tricky.
When you're dealing with tankrepairs, 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 thisrecognized industry standard and
(13:19):
these recognized, thesecertified individuals.
They're going to oversee thingsand at the end they're going to
write a document that says thistank's good to go and you got
to make sure your regulator'sgood with that.
In most cases you have the SPO31 standard and the API 653
standard.
Those are the standards used inthe industry and it has
certified people involvedholding their thumb in the air.
(13:42):
That's good enough to satisfythe authority having
jurisdiction.
Somebody qualified has saysthis tank is good to go.
Originally it's the listinglabel you have on the tank.
Now it's a qualified inspectorthat says between the listed
product that originally showedup and the modifications made
and all these steps followed,this tank is still good to
(14:04):
receive product.
So that's the listing part.
The warranty part's a whole lotmore tricky.
Because the warranty.
Warranties can come frommanufacturers or from
third-party warranty providers,but they're warranting the
product that the manufacturerproduces.
So either the manufacturer says, here you purchased my product,
(14:24):
I'm going to say for one year,you're good for material and
workmanship issues, or they canbuy a policy from a tank insurer
.
The Steel Tank Institute doesnot insure tanks.
There is an organization calledthe Steel Tank Insurance
Company that we do work with.
That does so.
We're different entities butthey're still only warranting
(14:45):
the original manufacturers.
The purchaser of the warranty isthe tank manufacturer and so if
you go start messing with thetank and changing things, well,
that isn't what the manufacturerbuilt, so that may not be
warranted.
I mean, I'm not going toguarantee you that it's going to
void the warranty, but I can'tguarantee you the warranty is
(15:06):
going to be there.
So you have to be reallycareful, you know.
And then why are you changingthis tank?
Are you repairing damage?
Did something else happen Again?
So yeah, most manufacturerwarranties are only one year.
The extended warranties that goon longer, that's very
difficult to establish.
I mean, if it's like adding aminor fitting and a problem
(15:26):
later didn't affect that fitting, the warranty may still cover
you.
But I can't guarantee anything.
I did talk to one warrantyprovider and that's what he told
me.
So yeah, you're kind of puttingthings at risk.
Shannon Oelkers (15:38):
So functionally if you're going to repair the
tank, if there's somehow awarranty in place.
Most of the times I've seenthis 31 applied.
The tank is well past that oneyear, but I did want to talk
about it a little.
Joe Mentzer (15:50):
If you have the original manufacturer make the
change, then you still might bein good shape.
Shannon Oelkers (15:57):
Let's ship it all the way back to Lakewood.
Joe Mentzer (16:00):
Well, maybe it's more down here in the
Continental, but there are sometank manufacturers that have
service departments.
Shannon Oelkers (16:07):
Oh, that will come and actually do it.
Joe Mentzer (16:09):
They not only build the tank, install the tank,
they service the tank.
That's good to know, andoccasionally we do have a case
where somebody ships a tank,buys a tank, ships it and all of
a sudden we came up one fittingshort.
Can you please come and installone more fitting?
And some guys will, some won't.
Shannon Oelkers (16:29):
Okay.
So, Craig, how does that playinto the SPCC?
If you're going to have a tankrepaired under 031, do we need
to alter the SPCC at the sametime?
Or update amend.
Craig Fletcher (16:41):
Yeah, I think that has to depend on what the
scope of the actual repair ormodification is.
Is it's really kind of the partthat you can sort of get into
that world of?
Does it have a material impacton the ability of the facility
to discharge from the property?
It's probably a site specificthing based on what they're
actually intending to do.
(17:02):
Just one last thing about thelisting issue is that you know,
in current practice.
In current tank installationpractice, virtually every tank
that's going to be installednowadays of the shop fabricated
design is going to typicallyhave some kind of listing
afforded to it, whether aCUL-142 or Southwest Research.
(17:23):
We don't normally see peopleputting in custom specialized
tanks that have to go throughsome really elaborate design
review by the fire department todetermine whether they're
suitable.
That's just not really apractical thing, right?
But if you are going to go inand do something like welding on
a UL listed tank or cut a newhole in the top for another
fitting, you're definitely goingto be affecting the listing
(17:46):
status of that tank.
So in California and otherjurisdictions where that listing
is so important to firemarshals, that can really affect
your ability to what may workin that situation.
However, that's going to varyby your local jurisdiction.
So in some cases you know itmay be something completely
different.
Your mileage may vary put itthat way with your local
(18:08):
jurisdiction.
Shannon Oelkers (18:10):
So maybe a good catch-all, if somebody's
sitting in the projectmanagement seat, is that they
should let their SPCC writerknow that they're modifying the
tank so that, if it applies,they are not leaving it out of
an SPCC amendment if it'srequired.
Craig Fletcher (18:24):
Definitely.
Shannon Oelkers (18:25):
Okay, so we had this question come up actually
just a month or two ago.
Can you still use SP31 if youdon't know the original
construction details for yourtank, like the labels?
It's fallen off or is illegible?
We're not really sure if it wasa UL-142, but we're assuming.
Can you still apply the 031?
Joe Mentzer (18:46):
You know the standard kind of addresses that
you have to look, you get backto that listing issue.
If you don't know theconstruction standard, how is
the tank listed?
And also what's the tankholding and are you required to
have?
So it doesn't prevent you fromusing it, but I guess in the
circumstance that you're usingthe tank you have to know that
it's suitable for the purposethat it's being used for.
(19:09):
Also, you have to have thatdiscussion with the authority
having jurisdiction.
If you told the authorityhaving jurisdiction I don't know
what the listing is on thistank but I want to change it
he's probably going to go to the.
Well, you don't know thelisting on this tank, then why
are you using it in the firstplace?
So it gets a little tricky,
It's Alaska so we use whatevertanks we can find.
(19:30):
Yeah, the standard says you can, as long as you
understand the construction ofthe tank and you take the proper
steps.
But we go back to that thingCraig talked about.
The owner's got to make surethat the tank is suitable for
use, and that also even goesback to the SBO.
It's up to the owner to makesure things are suitable for use
.
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Joe Mentzer (20:36):
Now I will tell you I have seen a lot of unlisted
tanks used for storing thingsthat aren't regular, like
asphalt cement, because it's nota liquid.
And you look at them andthey're really UL tanks.
And that's because the ULstandard is a good shop
fabrication standard.
It works well in a shop.
So does the API 12 series.
Other industries just use itbecause it's a recognized
standard.
(20:56):
They just don't pay the extramoney to buy the UL label.
Shannon Oelkers (21:00):
We do see that sometimes where it was
constructed for some otherpurpose, but now they're using
it for fuel.
Joe Mentzer (21:06):
Yeah, I've also seen some tanks built in like
South America, where some veryskilled metal workers collected
a bunch of scrap steel and putsomething together.
It's like, oh, that's not evenyou know.
Great work, guys, but not evenclose.
Craig Fletcher (21:21):
And, getting back to your example, I would
think too that you are going tohave tanks that are not have a
listing right.
We talked about API 12F or API650, appendix J.
Those are not true listings butthey are recognized standards.
So that is definitely allowedand it is very common to go out
to older facilities inparticular where you almost have
(21:43):
to make some kind of assumptionbased on your best examination.
Was it built to a shopfabricated standard?
Probably.
Which was it?
Well, I did some steelthickness testing on it and I
know by the design this isprobably following a UL standard
, but I can't say for certain.
But I think those are kind ofwhere a certified inspector or
(22:04):
other knowledgeable party may behelpful in guiding that.
You know the use of that.
But I think SP-031 certainlyallows discretion for owners to
be able to use that in thoseconditions where it's not.
Joe Mentzer (22:16):
You got to keep the regulator happy.
Shannon Oelkers (22:19):
So what I'm hearing is, if you have a tank
and you're uncertain of itsconstruction standard, either
due to age or loss of recordkeeping, it may be wise to
include a certified STI or APIinspector on the team that's
helping you with this capitalimprovement project, and or a
mechanical or structuralengineer that's familiar with
this product, the type of useand the fire codes, to be able
(22:41):
to give the blessing from theengineering side of things
rather than just relying onassumptions.
Okay, that sounds good.
I think those are good,actionable steps to take.
If you've got a tank, you'renot sure of its history, then
you can just add those to theteam.
I was wondering if you guyscould go over some common
repairs or modifications that dooccur in shot belt tanks,
(23:01):
because I do think thatsometimes the standard is
brought in and maybe I don'tknow like.
I'm just curious, like what arethe most common versions of
repairs and modifications thatoccur under it?
Craig Fletcher (23:13):
It's not particularly common, at least
here in California, because manytimes it's maybe more cost
effective to simply replace thetank.
But I can tell you in othercases it ranges a gamut from
something as simple as welddeposition, like puddle welding
to fill in.
If we're doing an internalinspection, we have corrosion
pits.
That's pretty common.
(23:33):
If we have gone into a tank orwe've seen reworking substandard
welds or cracking areas ofcracking those are pretty common
.
Or if you do have areas whereyou have corrosion or damage to
the tank, replacing certainsections using either patch
plates or insert plates,patching over it or inserting a
new piece of steel to match thecurvature there.
(23:55):
So I would say those are someof the most common ones that you
would probably encounter out inthe field Particularly.
I'm just trying to think alittle bit about some of the
challenges you face in Alaskaand what the genesis of these
repairs are.
But I would suspect some ofthose have to do with corrosion
and that or that's probably themost common one there, I would
think.
But I don't know.
(24:15):
Joe, you got anything to add tothat?
Joe Mentzer (24:17):
Well, in the Midwest the issue is bottom
replacement on verticalcylindrical tanks, and that's
because people let the leavesand junk build up in the bottom
of their dikes and let them holdmoisture in the bottom inch or
two or just all beat up, rottenaway.
(24:38):
So that's not an uncommonrepair.
Occasionally get some localizedcorrosion on the shell for
whatever reason.
Usually again it's somethingwet, got up against the side of
it and they ignored it for toolong.
And, yes, they put a patchplate over the top and make sure
that it's sealed up to theoriginal tank.
The original tank hasn't failed, but it's just got a thin spot.
So, yeah, those are the commonrepairs.
Occasionally I've done someinsert patches again due to
(25:00):
really just poor housekeeping onthe outside, on the inside
that's where the bottomreplacement comes in.
And then occasionally adding anew fitting on top of the tank.
Change in service, change inoperation we need another
fitting.
But again and Craig hit thepoint too often Occasionally,
adding a new fitting on top ofthe tank Change in service,
change in operation, we needanother fitting.
But again and Craig hit thepoint too often, once you've got
the tank cleaned and ready togo, yeah, well, you know,
(25:21):
instead of adding this newfitting, 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 (25:25):
Yeah, some of the ones we've seen lately.
I've seen a couple of steelsaddle support repairs where the
steel supports were corrodingand failing to support the tank.
There was some buckling.
And we've also seen themremoving bottom appurtenances
and moving them to the top.
Like the tank was older and ithas a water draw on the bottom,
but they maybe want to use itfor aviation, so they remove
(25:47):
that, patch it up and then movesomething to the top rather than
having it extrude from thebottom and then, of course, the
corrosion patches.
That's the number one reasonthat we get 31.
That's usually why the tankcannot continue in service
without a repair, and that'swhat's driving the use of this
31 is that they can't afford toreplace it.
Patching it is probably cheaper, or they've determined it to be
(26:07):
cheaper and they move on.
I also had a note here.
Are there any modificationsthat are not covered by 31?
And if there are, why aren'tthey covered?
Craig Fletcher (26:16):
So there are some provisions under Go ahead,
Joe, as I say there really is.
Joe Mentzer (26:21):
Sbo 31 says here's the repairs you can make and
here's the modifications you canmake.
So you got to be careful.
You can't, and you also have tohave some recognition of the
original tank listing as well.
You know things like increasingthe size of the tank that's not
covered under this standard,turning a horizontal tank into a
vertical tank Again, thatwasn't how it was designed to be
(26:43):
.
There's things that an engineercan do.
The term is called aconvertisontal and Craig taught
you that one Convertisontal.
Shannon Oelkers (26:50):
I have photos of a few of those that I have
encountered't go redesigning thetank or, you know, changing its
(27:13):
original intent significantlyin a repair.
Joe Mentzer (27:17):
That's where you maybe need a new, probably need
a new tank.
At that point you're probablybetter off just buying a new
tank.
Or you need an engineer andthen there's certain damage that
we can't account for in repair.
You know the tank I get thistent.
My tank's been in a fire, it'sbeen baked, great it's done.
Nobody, nobody's going to saythat tank's good to go.
(27:39):
Your insurance is probably goingto cover it.
Yeah, yeah.
Or what's the other one?
Guy had a tank in a undergroundvault.
The vault filled with water.
The tank floated, bent water.
The tank floated bent all ofthe fittings over on top.
Just you know how can I fix it?
You can't, don't even wasteyour time.
So yeah, there are absolutelylimitations.
Craig Fletcher (27:59):
So I would say too, Shannon, and some of that
within the specific portions ofit.
There's other examples wherethings where you're going to
need engineering assistance,You're going to kind of step
outside of the scope of SP-031for at least parts of it, If
you're designing a new anchoragesystem for a tank like you're
going to put new anchor chairson a tank or doing it, you're
(28:19):
going to have to have someengineer involved to help you
with the structural aspects ofit.
If you have pipe penetrationsthat are greater than 12 inches
below the liquid level, now youhave to start thinking about
what are we going to do toreinforce that location and at
that point then again you'reback into some more of the
engineering side of it as well.
(28:39):
So, changing the height of atank, adding another course to
the top of the tank, that's notcovered under the
run-of-the-mill SP-031 standard.
It can be done, but it's goingto be outside the scope of the
standard.
So I think and Joe can speak tothis but I think most of what
SP-031 is for is to reallyaddress the common repairs and
(28:59):
alterations you might have atank, give the owner and the
industry guidance on what can bedone and what's not allowed to
be done, including restrictionson where you can do certain
welds or repairs.
But it certainly can't accountfor every possible thing that's
out there, particularly formajor modifications for tanks.
Yeah, Okay.
Shannon Oelkers (29:19):
So if you're sitting in that project
management chair, it's good tobe aware that there are limits
to what can be handled under the31 standard and if you need to
go outside of them, that's fine.
But you've got to have somekind of engineering presence to
guide that and to make sure thatthe contractors are meeting all
of the different engineeringstandards and fire code
requirements and regulatoryrequirements that go with those
(29:41):
major repairs or revisions.
And the 31 is limited to somevery specific ones and you
should know which ones they are.
If you're going to be modifyinga tank Okay Right, that sounds
good.
Related to that, tank repairsrequire multiple types of
qualified personnel.
I was wondering if you guyscould review what kind of
contractor qualifications mightbe needed to perform the repairs
(30:02):
and the inspections, becausethe SPI, sc-31, it talks about
what you need to have for repairand then what you need to have
to qualify for inspection.
Could you guys address thosetwo pieces?
Joe Mentzer (30:13):
You need an SP001 inspector because they have to
inspect the tank and one of theimportant things is make sure
you thoroughly inspect the tankbefore you perform a repair,
because the last thing you'regoing to do is fix this one
little spot over here and ohwait a minute, you got this huge
problem over here.
Any welding done, you have touse a certified welder, so make
sure that that welder isqualified.
(30:34):
You may have to do somenon-destructive testing after
the repair is made and,depending upon the testing, you
got to make sure that the persondoing the testing is qualified
to do that testing.
And then you may have to testthe integrity of the tank.
I don't think there's anyparticular qualification to do
an integrity test, but make surethe person knows what they're
doing, because otherwise theycan do more damage.
(30:56):
We've seen that happen a fewtimes.
The problem is each repair canbe a little bit different, so
that the people involved mayneed to be a little bit
different.
But these are kind of specificskills.
You know, I've seen lots oftanks.
Oh, you know this beautifulfour-inch perfectly square patch
on the end of a tank welded inwonderfully yeah, that's great.
(31:18):
Minimum patch is six inches,supposed to round the corners.
That's the sort of thing yousee when people don't understand
the standards involved in them.
Craig Fletcher (31:27):
I'd also add one thing to that too, shannon,
that you know, under thestandard for people that can
qualify to do repairs, that alsoincludes welding personnel at a
facility that actuallymanufactures STI, API, ul or
Southwest Research Tank.
So those fabricators, althoughthey're not explicitly certified
(31:48):
welders like we think underASME or other things, they are
also qualified under thestandard to make those repairs.
So there's some specificlanguage in the standard who can
do what?
So you definitely want tofollow that, particularly if
you're maybe a contractingofficer or someone else trying
to put together a spec packageor a bid package for someone,
(32:09):
making sure they know who thequalifications are, because you
wouldn't want to go through thiswhole process and have someone
who's not qualified, right?
No, similarly, the inspectionscan be done, like Joe mentioned,
from an STI certified inspector.
Inspections can be done, likeJoe mentioned, from an STI
certified inspector.
It can also be a API 653inspector or it can be a person
who's employed by a manufacturerof people that make STI or API
(32:32):
or UL tanks or SouthwestResearch tanks.
So there's a little bit more ofplay in there, designed for
because I know in my experiencetrying to get sometimes back to
the fabricator.
If you can to help you can be agood approach if they've
already perhaps built the thing.
Having said that, your mileageis going to be different up in
Alaska, where you're at remotelocations where you won't have
(32:55):
that luxury.
Shannon Oelkers (32:56):
So that's kind of the other basis it's good to
cover, though, because we have apretty significant listenership
in the state of Washington andthe state of Oregon as well, and
they can absolutely interactwith their manufacturers.
They're present All right.
So if contractors are followingSP 31, they should be providing
a final report or record of allthe modification, repairs and
testing that occurred.
(33:17):
I personally can attest to awide interpretation of what this
report should look like andinclude.
Could you maybe review what afinal report should look like?
I'm hoping that thesecontracting officers and project
managers and owners could beset up to expect a certain
quality or a certain what theyneed to get back in that report
to show regulators and the SPCCplan writer that the repairs
(33:42):
occurred, because I have seeneverything from a one-page
checklist that's hand-filled outwith a mechanical pencil to a
proper report with lots ofsupporting documents.
So maybe let's go over what aproper report would look like.
Craig Fletcher (33:53):
I can talk a little bit about that one.
And basically, getting back tothe contracting officer or
someone trying to set up aspecification, the standard
itself has some specificrequirements.
It says that it has to showthat the repair or modification
that was done was doneappropriately.
The testing and remember, foreach type of repair or
modification you're going to do,there is an inspection and some
(34:17):
type of testing required forthat.
It's going to vary based onwhat the scope of the repair is.
Some may be just a simplevisual inspection, some may be
more involved.
So this is all covered withinthe standard.
So I would think that if I wasa contracting officer having
access to what the standardexplicitly says, if I'm trying
to set that up, I woulddefinitely include that.
(34:38):
There's also a discussion of howin SP-031 talking about is the
design and meeting the standardand code compliance after the
repair or modification was doneand there should be at least
some overview of what was somedescription of what the repair
or modification was done.
That seems prettystraightforward and there's
(34:59):
documentation that's completewith that.
So we do see this on the 653side where they have.
There's similar requirementsthere.
But Appendix B of SP-031 has afinal inspection form in the
back there that can help guidethat documentation 001
(35:24):
inspection.
Typically, what we want toinclude in a report like that is
a summary of what was done,what testing was done, what
repairs were done, the testreports, whether they passed or
failed or what the results of itwere, sketches of the area that
was repaired or modified andphotographs of what the work and
any other materials.
You may include thequalifications of your welders
or you may include other thingsof that nature that apply to the
(35:46):
actual modification or repairthat's done.
But it's a very important stepand as an owner, you clearly
want that.
You definitely want that inyour back pocket for your own
protection, because if you havehad repairs done, I would expect
that someone at a regulatoryagency may request that, because
they'll probably look at yourtank files as part of the SBCC
(36:07):
plan inspections.
So that's kind of what I wouldcertainly say.
Joe Mentzer (36:12):
You've hit one of the important points.
At some point, some qualifiedindividual is going to look at
this tank and say, hey, whathappened here?
I have my list and my list saysyou know one is there should be
some summary or finding on theoriginal.
Why are you doing this repair?
Maybe it's back to a tankinspection report where problems
were listed, or you know therequest that I needed out of
(36:32):
fittings for some reason.
But why is the repair done?
Certainly, documenting theoriginal tank construction
standard, whether you'vedocumented it or this is what
you believe.
But that AST record, theoriginal one's good and you may
need an updated record dependingupon what changes are made.
Certainly you know a summary ofeverything done by the repair
(36:53):
firm at this time.
So that way, in 20 years, whensomeone does the next formal
inspection, why is this patchhere?
Oh, okay, here it wasdocumented.
You know, again, got to throwsome crumbs out for the next
inspector who's going to betrying to figure out what you're
doing.
Certainly, yes, thecertifications for people
involved, the results of anytesting, depending upon the
(37:14):
level of testing.
If you do an integrity test,that record should be kept.
Certainly, if you've done sometesting, you want credit for it.
And then finally, if theauthority having jurisdiction,
like Craig, said they may beinterested, they may need to
come and reinspect the tankbefore 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 patchon the tank.
Shannon Oelkers (37:35):
Or more.
So keeping it for the life ofthe tank is important as well.
Like this is a document thatcannot be forgotten or left in
an email.
It absolutely has to beincluded in the file for that
specific tank once it occurs.
Joe Mentzer (37:47):
I learned from my predecessor it's good to leave
notes.
She left me some things andthings.
Oh yeah, that makes sense now.
So leave the next individualsome information to help them do
their job.
Shannon Oelkers (38:00):
I think with the STI standard, what does make
it a little more difficult isthat you've got 20-year
inspection intervals for a classone tank and in 20 years you
can have multiple turnovers in ajob, and so we definitely focus
on keeping it for the life ofthe tank, keeping it hard copy
where the tank lives, not justin digital land but in multiple
places, and then our firm, ofcourse, keeps records forever so
(38:23):
you can go back to us even ifyou didn't keep it internally,
which has happened sometimes.
So we've talked a lot aboutwriting bid packets or
specification packets.
Do you guys have any pro tipson how to write this standard
into a proposal or an RFP or aspec package to make sure that
when you send it out, the bidsyou're getting back are going to
be compliant with this standard?
Craig Fletcher (38:44):
I think on that.
Shannon, you're going to haveto have somebody on the owner's
side have access to SP031,because that's really that's
your guideposts on what you arerequired to do.
It's not available anywhereelse.
I mean it's going to comestraight out of that standard.
So having that is certainly one, and trying to incorporate to
(39:04):
the extent you can in that bidrequest the specific items that
people have to do when they aredoing repairs and modifications
to tanks.
The other part of it too is thatand I don't know, I'm sure it
depends on the actual bidprocess or spec you're preparing
is that it's not particularlycommon to have the petroleum
(39:26):
contractor or the repair companybe the same as the inspection
company.
So in that case there is abenefit to having some
separation there.
That's another consideration,because there could be some
conflict of interest issues withthat.
So that may be something forprocurement officers to think a
little bit about how we're goingto get this work package
(39:48):
together, who's going to do whatand who's going to retain the
individual parties for that.
So in my experience, relyingsolely on a contractor to do
everything, when we actually andyou know this as a plan writer
is that we need something thatwe can hang our hat on to go
with our SPCC plan, which is aregulatory compliance document.
(40:08):
So that's where we want to endup at the end of the day, to be
able to have that.
So that's kind of what I wouldthink might be something
worthwhile for those who want todo bid requests for something
like this to keep in mind.
Joe Mentzer (40:19):
There are some firms that do regular repair on
tanks or industrial stuff andunderstand what they're getting
into, and it's certainly it'sgood that the person that you're
contracting understands whatthey're getting into.
Getting them to come and have alook at the tank is always
important.
Making sure they understand therules that are in play at the
(40:41):
facility, depending upon the.
You know, if you're workingdeep in the heart of an
industrial facility, they canhave some pretty significant
rules on what you can and cannotdo.
It increases their time andtheir effort, so you got to make
sure they understand thecircumstances associated with it
.
And making sure they understandthe hazards associated with
(41:01):
either the materials they'reworking around or materials
they're working with isimportant as well.
Shannon Oelkers (41:06):
So providing a good, clear description of the
facility, the products they'reworking with and the general
environment.
Making sure that you're listingout the qualifications needed
for the actual repair andmaintenance, separating the
inspection from that to avoidconflict of interest.
Spending the couple hundreddollars to actually buy the SP31
standard and reading it priorto starting the project.
(41:27):
And then I think I would add,making a nice clean list of
deliverables and say finalreport, including photo log,
including report data, includingnon-destructive testing results
in PDF or something like that,so that it's all together.
It's not 27 emails of 27documents which we have
definitely gotten before.
(41:47):
So assembling it into that kindof a final report, okay, those
are all really good tips.
I agree with you that justpurchasing the SP-31, it is not
that long, it is not thatcomplicated, but you do need to
have it if you're going to bedoing repairs to a tank at your
facility.
Okay, so I think that'severything I have for SP-31.
Does STI SPFA have anyadditional resources for our
(42:09):
listeners if they want to learnmore about this standard, sti
SP-31?
Joe Mentzer (42:14):
Actually, on August 11th we're doing a webinar on
SP-031 and more so on thingspeople do wrong with it, so that
one is coming.
We've done that.
One did that out for the Coupafolks in California did it down
at the National Institute ofStorage Tank Maintenance
recently.
We're going to do that as awebinar coming and our website
(42:37):
does have the Frequently AskedQuestions section, which does
address some things.
That's certainly a good placeto look.
The whole STISPFAorg website isa great place for information
on storage tanks how to properlymaintain them, how to properly
operate, how to properly repairthem.
So yeah, there is someinformation available and
talking to a qualified inspectorcertainly helps.
(42:59):
They should understand that theAPI guys, the STI guys it's
similar repairs.
Shannon Oelkers (43:06):
Great.
Thank you both so much fortaking the time today to go
through that standard with us.
Like I said, we're just seeingit used so much more.
I'm definitely going to tune infor that August webinar because
I think it does help to knowwhat to avoid and to be aware,
and so I would encourage all ofmy listeners.
And then to clarify we'rerecording this in 2025.
So that'll be live August 11thof 2025.
Joe Mentzer (43:27):
10 am Central Time.
Shannon Oelkers (43:28):
Ooh, 10 am Central Time, which would be
what 6 am 7 am Alaska Time.
I thank you both so much forcoming on.
I really appreciate it.
Do you have any final wordsbefore we log off for today?
Craig Fletcher (43:40):
No, we're always happy to answer questions off
for today, no we're always happyto answer questions, so if
anybody has anything, Iappreciate it.
Thanks for having us.
Awesome, yeah, thank you forhaving us.
Shannon Oelkers (43:47):
Thank you both for coming.
I just appreciate having bothof your expertise.
It truly was a pleasure andjust wonderful to hear all this
stuff and learn.
I appreciate it so much.
Joe Mentzer (43:57):
Thanks, happy to help.
Shannon Oelkers (44:01):
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 tomake sure that you knew the
following this podcast is forinformational purposes only and
should not be considered legalor regulatory advice.
We are not responsible for anylosses, damages or liabilities
that may arise from the use ofthis podcast.
(44:22):
This podcast is not intended toreplace professional regulatory
or legal advice, and the viewsexpressed in this podcast may
not be those of the host thatwould be me or Integrity
Environmental.
Thank you very much forlistening 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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