Advanced Aboveground Storage Tank Inspections – In-Service Robotics

Tank Inspections

By

Vineet K. Masuraha
Stacy Carr

Trinity Consultants
12801 North Central Expressway, Suite 1200
Dallas, TX 75243
(972) 661-8100
emails: vmasurah@trinityconsultants.com, and
scarr@trinityconsultants.com

Presented at

NPRA
2004 National Environmental & Safety Conference
September 27 and 28, 2004

San Antonio, Texas

2004 Copyrights Reserved by

ENV-04-182
Page 1
Abstract
This paper describes the advanced in-service tank inspection methods available for use in the
inspection of aboveground storage tanks (AST) in the petroleum and petrochemical industry. ASTs
are subject to several federal and state regulations requiring tank owners to perform tank floor/bottom
integrity, seals system, and deck fittings inspections on a routine basis. The conventional procedure
for this type of inspection requires tank owners to drain the tank and clean it with water or solvents,
empty sludge residue, and manually inspect the tank. The impacts associated with draining and
cleaning the tank, temporarily storing tank contents, waste disposal, excessive emissions, safety
hazards, human subjectivity, inaccessibility and inaccuracy, and operational downtime make this
procedure inherently a safety risk and undesirable for environmental and economic reasons.

Advanced robotics technologies for tank inspections, which do not require taking a tank out-of-
service, are commercially available through several vendors. The robotics technologies use a
remotely operated robotic inspection vehicle submerged in the tank liquid for tank floor/bottom and
primary seal inspections. The remotely-operated high-resolution cameras are used from the tank top
for the deck fittings and secondary seal inspections. The major advantages of using the robotic
technologies over the conventional methods of performing tank inspections are improved safety,
reduced environmental impact, enhanced quality, and reduced costs.

Introduction
This paper describes the tank inspection requirements (such as New Source Performance Standards
[NSPS], 40 CFR 60), conventional inspection techniques (out-of-service, manual, confined space
entry, and visual), advanced inspection technologies (in-service robotics), benefits derived from using
these advanced technologies, and the status of approval of these technologies by regulatory agencies.
The authors also review the unique challenges and implementation circumstances associated with
advanced inspection technologies. Finally, the authors present a pilot study currently in progress for
the application of advanced inspection technologies to an Internal Floating Roof (IFR) tank subject to
NSPS Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels)
requirements.

Regulations and Background

The testing and monitoring requirements for IFR tanks subject to NSPS Subpart Kb (as outlined in 40
CFR 60.113b [a] [4]) are:1

Visually inspect the internal floating roof, the primary seal, the secondary seal (if one is in-
service), gaskets, slotted membranes and sleeve seals (if any) each time the storage vessel is
emptied and degassed. If the internal floating roof has defects, the primary seal has holes,
tears, or other openings in the seal or the seal fabric, or the secondary seal has holes, tears,
or other openings in the seal or the seal fabric, or the gaskets no longer close off the liquid
surfaces from the atmosphere, or the slotted membrane has more than 10 percent open area,
the owner or operator shall repair the items as necessary so that none of the conditions
specified in this paragraph exist before refilling the storage vessel with volatile organic
liquid (VOL). In no event shall inspections conducted in accordance with this provision
occur at intervals greater than 10 years in the case of vessels conducting the annual visual

ENV-04-182
Page 2
 inspection as specified in paragraphs (a)(2) and (a)(3)(ii) of this section and at intervals no
greater than 5 years in the case of vessels specified in paragraph (a)(3)(i) of this section.

The proposed rule and notice of public hearing for 40 CFR Part 60 NSPS Subpart Kb, published on
July 23, 1984, provides the background and rationale behind the ten-year inspection requirements.2
An excerpt from the Federal Register (FR) Notice is provided below:

Some failures of the seal system may not be detectable during the visual inspection from the
fixed roof. Holes and tears are most likely to develop on the portions of the seal not visible
from the fixed roof. Additionally, visibility is limited by lighting and distance problems
during the inspection from the fixed roof. Because an internal inspection may detect failures
that would otherwise go undetected, there are advantages to requiring that the vessel be
emptied and degassed, and an internal inspection of the controls be performed. Inspection of
the control equipment from both the underside and topside of the internal floating roof can be
performed when the vessel is emptied and degassed.

The EPA then examined the frequency at which inspections should be required. The controls
required on the fixed roof vessels have a very low failure rate and are expected to last many
years when installed properly. Data indicate that vessels are generally degassed on the
average of once every 10 years for inspection as a typical practice. Therefore, if owners or
operators were required to perform internal inspections on their vessels at least once every
10 years, this requirement would, on the average, cause no additional degassings of the
vessel, and hence no additional emissions.

Consequently, since there are advantages to performing internal inspections on an internal

floating roof storage vessel and since they are inspected routinely on the average of every 10
years, the proposed standards require an internal inspection of each internal floating roof
storage vessel at least once every 10 years. If a vessel is emptied and degassed to repair a
failure detected by an annual visual inspection, an internal inspection must be performed.
This inspection will be substituted for the 10-year inspection, and another internal inspection
will not be required for another 10 years. This requirement will result in one degassing
where two would have occurred otherwise.

Although the United States Environmental Protection Agency (U.S. EPA) concluded that a 10-year
cycle of inspection for new tanks would not impose an additional burden on facility operators on the
average, there were dissenting opinions during the comment period, particularly from operators of
smaller facilities. These included the comments described below:3

2.3.3.2 Ten-Year Inspection

Comment: Three commenters (IV-D-7, IV-D-20, IV-D-39) said that the requirement that
IFRs be emptied and degassed at least once every 10 years is unreasonable for facilities with
only one IFR or where acceptable alternate tankage is not available. One commenter (IV-D-
7) requested that pipeline tank stations with only one IFR be exempt from these requirements
or that an operationally compatible method to empty and degas the tanks be allowed.

The Agency did not find merit in the dissenting comments. Their response noted:

As stated in the previous response, tanks in the chemical industry are typically emptied,
degassed, and cleaned every 5 years. Benzene storage vessels are typically emptied,

ENV-04-182
Page 3
 degassed, and cleaned on 10-year intervals. The Agency has determined that it is typical
industry practice to clean tanks on a regular basis and that the 10-year internal inspection
requirement is not an undue burden. The Agency has determined that no special provisions
are necessary for pipeline tanks. In many instances, alternate tankage such as an EFR will
likely be available. In any case, it is not unreasonable to require a facility with only one IFR
to conduct a planned, internal inspection every 10 years. Further discussion with one of the
commenters (IV-D-7) revealed that existing tanks were of concern. This NSPS will not affect
existing storage vessels; therefore, no changes have been made as a result of these comments.

Conventional Inspection Methods (Tank Out-of-Service)

The conventional methods present serious safety and environmental challenges. The IFR tank is to be
taken out-of-service, emptied, and degassed. This results in potential air emissions (or the need to
collect and incinerate, or otherwise dispose of the vapors), operations downtime, possible generation
and disposal of hazardous waste, cost of temporary storage of tank contents, and the cleaning and
maintenance of the temporary storage vessel.

The detailed procedure in common use by industry in conducting the 10-year IFR tank inspection is
outlined below in the following steps.

Step 1. Tank Preparation:

• Tank roof entry [made using confined space entry in order to set roof legs on high level
(if allowed)]
• Alternative storage of product
• Product transfer
• Tank lock-out/tag-out
o Valve alignment
o Line blanking
o Ventilation
o Atmosphere monitoring
o Emissions monitoring
o Regulatory compliance documentation

Step 2. Tank Entry

• Safety plan review
• Confined space training
• Personnel protective equipment training
• Open permitting
• Personnel liability issue resolution

Step 3. Tank Cleaning

• Atmospheric monitoring during cleaning
• Transfer and processing from cleaning
• Waste generation reporting
• Waste transportation
• Waste disposal
• Tank degassing

ENV-04-182
Page 4
 • Pollution liability issue resolution
• Use of lifts or jacks to raise roof to set on high tank leg level in order to allow sufficient
working space (if legs were not set on high level)

Step 4. Tank Inspections

• Tank bottom integrity
• Tank bottom settling
• Shell integrity
• Weld seam deterioration
• Roof integrity
• Seal tightness
• Deck fittings tightness

Step 5. Return Tank to Service

• Tank hydrotesting (if appropriate)
• Set legs on normal (low) level while roof is in float with water during hydrotesting
• Lock-out/tag-out removal
• Line blanking removal
• Valve re-alignment
• Product transfer
• If water was not used to float roof, set legs on normal (low) level after roof is
sufficiently in float.

In addition to the manpower and personal protective equipment (PPE), conventional inspections
require an array of equipment including hydroblasters and washing equipment, incineration blowers,
methane tanks, particulate filtration and collection systems, vacuum truck and waste containment
systems, and inspection and monitoring equipment.

The following factors are the typical economic considerations associated with the conventional
inspection method:

• Safety training for personnel

• Environmental clean-up and excessive emissions
• Alternative tank storage for contents
• Quality of inspection
• Draining and refilling
• Hazardous and confined space entry
• Waste disposal

Table 1 shows the numerous factors that a facility owner must consider prior to conducting an out-of-
service tank inspection.4

ENV-04-182
Page 5
 Table 1
Considerations for Conventional Tank Inspection Methods5

Alternate Inspection Technique (Tank-In-Service)

The new technology for the IFR tank inspections, which does not require taking a tank out-of-service,
is commercially available through several vendors.6 InTANK Services, Inc. (InTANK) is a leading
service provider for the robotic inspection equipment. The available technologies can generally be
categorized under the following three functional groups.

ENV-04-182
Page 6
1. Advanced technologies available for tank bottom and integrity inspections
2. Advanced technologies available for rim seal inspections
3. Advanced technologies available for deck fittings inspections

This paper does not address or provide any specific information on advanced technologies available
for the first category above (tank bottom and integrity inspections). However, the American
Petroleum Institute (API) has established a maintenance and inspection standard, API 653, to provide
guidance on an ongoing assessment of a facility’s storage tanks. This standard addresses tank bottom
and integrity inspections. In 1998, the API revised this standard to include “remote-sensing”
techniques, stating:7

If the internal inspection is required solely for the purpose of determining the condition and
integrity of the tank bottom, the internal inspection may be accomplished with the tank in-
service utilizing various ultrasonic robotic thickness measurement and other on-stream
inspection methods capable of assessing the thickness of the tank bottom, in combination with
methods capable of assessing tank bottom integrity as described in 2.4.1.

Thus, the revised API 653 standard now allows the use of robotics as an alternative method for
assessing the condition of a tank bottom/floor as long as certain conditions are met. As a result of this
revision, quantitative tank bottom/floor remaining life data can now be integrated with the balance of
the external inspection elements in order to provide a broader assessment of the tank’s condition
without taking the tank out-of-service. As a result of the API acceptance, several state agencies have
allowed tank owners to conduct the tank bottom and integrity inspections using the robotics
technology. For example, the New Jersey Department of Environmental Protection, Bureau of
Discharge Prevention revised the guidelines for the inspection and testing of Above Ground Storage
Tanks (ASTs). The revisions included the acceptance of the use of a robotics instrument to visually
inspect the tank interior (i.e., bottom and shell) for API 653.

The robotics technologies for the second and third categories allow inspections for the primary seals,
secondary seals, and deck fitting components required for NSPS Subpart Kb. With the availability of
the robotics technology, a facility operator can fully comply with the provisions of NSPS Subpart Kb
without removing the tank from service.

Rim Seals Inspection Technique

As shown in Figure 1, the inspection of the primary and secondary seals could be easily accomplished
with the use of the On Stream Tank Inspection System (OTISTM) and the Quick-Look-Remote
Inspection and Measurement System (QLRIMSTM), respectively.

InTANK designed two complimentary robotics devices that are used together for the inspection of
seals on IFRs. Two different inspection approaches are necessary due to the dual seal design of many
IFRs. One part of the seal is in contact with the product (the primary seal) and a second part is
exposed to the vapor space of an IFR (the secondary seal). The primary seal is inspected using a
remotely-controlled camera installed on a robotics floor inspection system. This system, the OTISTM,
is deployed inside the tank’s product (i.e., below the IFR). The secondary seal is inspected using a
remotely-controlled high resolution camera with laser range finders. This system, the QLRIMSTM, is
deployed from the manway of the fixed roof above the IFR. In all cases, the inspections are
conducted while the tank is in-service, avoiding the need to drain and degas the tank, and eliminating
the need for confined-space entry. The OTISTM primary seal inspection robot incorporates an

ENV-04-182
Page 7
advanced camera system and measures seal gaps between the roof seal and the shell with great
accuracy. The QLRIMSTM, uses a laser ranging and measurement system that inspects the secondary
seals of internal floating roofs while in-service and without manned entry. Both systems are designed
to detect seal damage or failures (tears, holes, gaps between the seal and the shell, etc.) and measure
the extent of the damage directly through the use of a laser rangefinder in the case of the OTISTM or
through extrapolating damage through the use of a nomograph, in the case of the QLRIMSTM.

OTIS Inspection for Primary Seal Measurement8

The camera system of OTISTM is capable of assessing the condition of an IFR’s primary and
penetration seals from a distance of over 30-feet through clear products (e.g., light crudes, gasoline,
and certain intermediates). The vehicle has a camera and a light source for illuminating objects in the
near field of the robot. The light and camera are mounted on a tilting assembly pivoting about a rod
held by brackets attached to the vehicle. The camera and light source are focused upward onto the
tank sidewalls and the underside of the floating roof along the edge of the primary seal. The camera
enables visual assessments of the condition of the primary seal between the tank sidewall and internal
floating roof. Using available light or flooding the vapor space with artificial light allows the camera
to detect extremely low levels of light that may leak through the gaps created by a failed seal.

Figure 2 shows photographs taken from the OTISTM seal inspection system. The primary seal test
conducted with OTISTM was accomplished in a 93-feet diameter x 40-feet high gasoline tank with an
IFR. The tank contained approximately 32-feet of product with another 8-feet of vapor space
between the IFR floor and the product. The floating roof had a failed center column penetration seal.
The seal gap shown in Figure 1 was physically measured to be equal to 1/8-inches. A clear light leak
can be seen from this image demonstrating the sensitivity of the OTISTM camera to light sources over
30-feet from the face of the camera. This capability was confirmed in laboratory testing.

The OTISTM provides a more precise and consistent inspection than visual techniques. The high light
sensitivity of the OTISTM camera can detect minute gaps in the primary seal at high gauge and
provide a recording of the seal integrity at mid and low gauge. Additionally, nomographs can be
produced by measuring actual seal gap separations and relating them to direct gap measurements
from the camera image.

With this technology, the following objectives are met:

• Primary seal assessment with high resolution optical clarity (i.e., visible gaps, seal
detachment, holes, or openings, and tears)
• Complete video record of primary seal assessment using the OTISTM-G AST floor
inspection scanner

Figure 3 shows the OTISTM-G seal inspection scanner, which is capable of performing qualitative
measurement with high-resolution digital images.

QLRIMS Inspection for Secondary Seal Measurement9

The camera and laser system of QLRIMSTM is capable of quantitatively and qualitatively measuring
an IFR’s primary seals to 1/8-inches from a distance greater than 100-feet in the vapor space of the
AST. That is, the equipment can both detect and record seal integrity and provide precise
measurements of seal gaps against which it can be compared to the measurement requirements of
NSPS Subpart Kb.

ENV-04-182
Page 8
To inspect a secondary seal with QLRIMSTM the camera with integrated lasers is suspended from a
pole. The other end of the pole remains outside of the vapor space. It is held by a tripod positioned
above the manway. The camera laser sources are positioned around the camera lens in a regular
array, such as four lasers in a polygonal (e.g., square) array with each beam forming a corner of the
array.

The laser beams are aligned substantially parallel and straight. The QLRIMSTM laser beams do not
distort or bend when projected through the vapor space of an internal floating roof tank. A fifth laser
is mounted on the camera housing along one side of the grid. The fifth laser is offset to project at an
angle θ in the range from about +1 degree (°) to about +3° (or about -1° to about -3°) from an axis
parallel to the axis of projection of the lasers in the regular grid.

The lasers project an illumination pattern of a series of spots in a square grid with each spot separated
from an adjacent spot by 80 millimeter (mm). When the laser sources are projected onto the target at
an angle, the distance of separation between two of the spots may be different for two of the parallel
sides, but may remain 80 mm between the other two parallel sides, such that the illumination pattern
of spots forms a rectangle rather than a square.

A fifth laser projects a spot that is spaced apart from one of the spots by a distance of “x.” The “x”
distance may be calculated by simple trigonometry using a software algorithm. With this algorithm,
it is possible to calculate the distance between the camera and the target upon which the illumination
pattern is formed, as well as the distance of “x,” based upon predetermined parameters: (1) the angles
θ and λ, which may be the same or different, and (2) the separation between the lasers, and (3) the
spacing of the spots in the illumination pattern (based upon measured parameters). If the illumination
pattern forms a rectangle by connecting the spots formed at the corners, the distance for measurement
“x” is selected as the spot for “x” formed along the side between spots that measures 80-mm. If both
sides along which the spot is formed correspond to 80-mm, the camera and laser sources are projected
perpendicularly toward the target, and determinations of “x” can be made with reasonable accuracy.

Figure 3 also shows the QLRIMSTM inspection device, which provides capability to inspect a
secondary seal without manned entry into the tank. The device is intrinsically safe (certified by
Entela) and portable.
Figure 1
OTIS for Primary Seal Inspection and QLRIMSTM for Secondary Seal Measurement10
TM

ENV-04-182
Page 9
 Figure 2
Two Views of Light Leaks11

[The left hand photograph is a penetration seal gap taken from OTISTM while on the tank floor during a light
test from within the product. The right hand photograph is the same penetration seal light test from within the
product.]
Figure 3
OTISTM-G Seal and QLRIMSTM Inspection Devices12

Deck Fittings Inspection Technique

With the combination of technologies for the camera and laser system of QLRIMS and the camera
system of OTIS, the commercially available robotics system are also capable of quantitatively and
qualitatively measuring the deck fittings from a distance greater than 100-feet in the vapor space of
the AST from the top of the fixed roof and the bottom of the tank bottom.13 However, according to
the commercially available vendor the robotics technology train may not be able to inspect the
components that are not visible either from the top or the bottom side of the tank. The inspection
procedure for deck fittings is the same as explained in previous sections.

Benefits
The selection of robotics technology is a major advancement in achieving the environmental
objectives balanced with economic needs. The robotics technology performs inspections as well or
better than the currently approved conventional methods of performing tank inspections. There are a
number of reasons and advantages for inspecting aboveground IFR tanks by using robots while tanks
are full of product and on-stream. The rationales and benefits for selection of this technology as an
alternative to visual inspection are discussed below.

ENV-04-182
Page 10
Improved Safety

All of the conventional inspection techniques mentioned in previous sections exposes personnel to the
hazards of confined space entry. They also entail the risk of explosion and fire from accumulated
vapors and potential for damage of the top surface of the floating roof. In addition, equipment-related
confined space restrictions, such as the need for explosion-proof lighting, ventilation equipment, and
air monitors also increase costs and make the process time-consuming. Even industry’s best
management practices can not eliminate the safety, health, and environmental challenges of
conventional inspection processes.

The proposed alternative technique eliminates the safety issues associated with the seals and deck
fitting inspections. This method allows for a high quality inspection under the circumstances where
manned entry is not possible or not desired, improves the level of safety, reduces health risk
exposures and the possibility of accidents, and eliminates the need for confined space entry.

In addition, the robotics systems, constructed of non-sparking materials, minimize the potential for
property damage from the inherently explosive atmosphere at the tank roof. The vendors of these
commercially-available technologies apply rigorous testing and ongoing auditing to support their
safety certification process. As part of the product safety testing process, these vendors will certify
these devices against fire, parts failure, and engineering deformities.

Pollution Prevention and Environmental Benefits

The out-of-service inspections for IFR tanks require cleaning and degassing the tank. Cleaning and
degassing are necessary to allow workers to enter the tank to conduct the inspection. The degassing
emissions are those emissions that will be released from the tanks’ vapor space prior to cleaning, and
sludge emissions are released from the tank in the process of removing sludge from the tank during
cleaning.

U.S. EPA estimates total emissions of approximately 1.1 tons from degassing a tank of 200,000
gallons (gal) capacity.14 This document also states:

Depending on the method of disposal, the sum of the cleaning and degassing emissions may
be greater than the emission reductions obtained from the implementation of control options.
For this reason, it may be necessary to minimize the environmental impacts associated with
cleaning and degassing by requiring IFR tanks to implement the control options when the
tanks are out-of- service for their regulatory scheduled cleaning.

Another possible source of secondary emissions is the treatment, storage or disposal of tank
sludge and the rinsate from tank cleaning. The regulatory status of the sludge and rinsate
depend on the composition of tank contents. The sludge generated from the tank cleaning
process may be up to 90 percent liquid. Independent of any VOC emitted from the liquid
portion of the sludge, 3,000 gal of solid waste will be produced from cleaning a 200,000 gal
tank. This material may be RCRA hazardous wastes.

The inherent derivative benefits from automated robotics inspections are eliminating the need for
degassing, as well as the requirement to collect the emissions and waste materials. Therefore, these
reduced emissions and waste are considered when evaluating the costs of the alternative inspection
techniques.

ENV-04-182
Page 11
In addition to the VOC reductions, a paper published in Independent Liquid Terminals Association
(ILTA) annual operating conference (1999) states:15

According to the Texas Natural Resource Conservation Commission, substantial greenhouse

gas emissions occur during tank cleaning operations. The use of in-service inspections will
source reduce these greenhouse gas emissions by eliminating the need to drain, vent and
clean tanks prior to inspection. In order to avoid releasing greenhouse gases, such as
benzene and other chemicals on the Toxic Release Inventory, operators will typically burn
the evacuated fumes with methane and other gases to eliminate the VOC release.
Nevertheless, incineration generates significant CO2 emissions.

Current In-Service Tank In-Service

Resource Issues
Technology Inspection Savings
CO2 and VOCs (tons) 102.3005 .3003 102.0002
SO2 (tons) 0.0253 0.0028 0.0225
NOx (tons) 0.1720 0.0124 0.1596
Particulate (tons) 0.0328 .0025 .0302
Product Waste (Btu) 1,260,000,000 84,000,000 1,176,000,000
Man Hours in Confined Space 1,200 0 1,200
The above table represents typical pollution prevention and energy savings calculations that are associated with an
in-service robotics inspection of a 30 m. (100 ft.) diameter 13.8 m. (45 ft.) tall tank containing diesel. These
calculations assume best practices are being used to ventilate and thermally treat VOCs.

As shown above, in-service tank inspections have been proven to result in reduced emissions and
environmental impacts.

Higher Quality

The reliability of conventional inspection procedures is dependent on visibility and human’s

subjectivity and accuracy. The alternative inspection technique improves the quality of inspections
by recording high resolution imagery. The robotics inspections utilize an advanced camera and laser
systems, which measure the seal gaps and inspects the seals and deck fittings for damage or failures
with great accuracy.

Cost Reduction

Robotics technology offers several direct and indirect cost savings. The direct cost savings are
achieved by the reduction or elimination of hazardous waste disposal costs, environmental and
personnel exposure costs, and alternative storage costs. The indirect cost savings are achieved by
shortened turnaround schedules that eliminate tank outages and loss of productivity. The total direct
and indirect costs vary depending on the tank size, product, sludge and sediment content, alternative
tankage availability, and a host of environmental factors.

Summary of Benefits

In summary, the reasons for selection of robotics technology as an alternative inspection method for
NSPS Subpart Kb (40 CFR 60.113b [a][4]) requirements are listed below.

ENV-04-182
Page 12
 1. Reduces safety risks during the inspection process.
2. Promotes reduction of pollution (VOCs and HAPs).
3. Eliminates the need for taking the tank out-of-service and planning for alternate storage and
waste management.
4. Results in higher quality inspections (i.e., increased accuracy) than the conventional method.
5. Reduces the cost of inspection.

Status of Approval and Conclusions

The general provisions of the NSPS allow the regulatory agencies to accept alternative compliance
programs if the facility operator can demonstrate that the alternative meets the specific regulatory
requirements for the equipment. Several oil and gas companies are in the process of obtaining
agency’s approval of alternate inspection programs under 40 CFR 60 Subpart Kb Section 113b (a) (4)
using an advanced robotics inspection technology. These alternate inspection methods would allow
these companies to conduct inspections under safe conditions with reduced emissions and costs.
Table 2 provides a comparison between the conventional and alternate inspection techniques.

Table 2
Summary Comparison

Conventional Inspection Technique Alternative Inspection

(Out-of-Service) Technique (In-Service)
Procedure
Tank draining, cleaning, waste
Required Not required
management, other requirements
Confined space entry – training, Minimal confined space
Required
ventilation, and monitoring entry
Alternate storage Required Not required
Tank degassing and cleaning emissions Required Not required
Recommissioning and refilling Required Not required
Benefits
Effectiveness of Inspections Limited for tank top inspections Reliable and effective
Subject to human subjectivity,
Accuracy Greater accuracy
accessibility, and safety challenges
Environmental impacts VOCs and HAPs emissions Minimal emissions
Cost effectiveness Very expensive Reduced costs

The robotics technology described in this paper serves as a method that is equal to or an improvement
upon current inspection techniques. The robotics inspection technique has been recognized as an
alternate inspection technique by the U.S. EPA Region II, North Carolina Department of
Environment and Natural Resources (NC DENR) for NSPS Subpart Kb inspections, and New Jersey
Department of Environmental Protection (NJ DEP) for tank integrity inspections.

A letter from Mr. Daniel Manasia, Air Compliance Branch, U.S. EPA Region II, supports and
endorses the use of robotics technology.16

ENV-04-182
Page 13
 Mr. Morris expressed to me that he could see no reason why a robotic inspection would not
satisfy the NSPS for storage tank inspections, since the rule only required that “visual”
inspections be performed. The seal gap analysis, required by EPA guidelines, can also be
accomplished with laser measurements, as provided in your supporting documents.

A letter from Mr. Myron G. Whitney, Regional Air Quality Supervisor, NC DENR, also supports and
endorses the use of robotics technology.17

The second alternative method would employ a remote controlled robot equipped with a
camera to be submerged inside the tank and inspect the primary seal from the bottom side.
This method is acceptable and also slightly preferable to the manned method both for safety
reasons and for accuracy since the space above the floating roof can be flooded with light
that will readily aid in detecting gaps in the seal.

Authors of this paper recommend that if the reader intends to use the robotics technology in-lieu of
the NSPS Subpart Kb inspection requirements, then proper endorsement and authorization must be
obtained prior to conducting the inspection using this technology. The authors also do not take any
responsibilities related to the limitations and services of vendors providing these commercially
available technologies.

Acknowledgements
The authors are grateful to Mr. Wesley B. Crawford of ExxonMobil Pipeline Company for his
constructive comments during the development of this pilot study. The authors also wish to
acknowledge Mr. Daniel M. Quinn of InTANK Services for the comments and information provided
by him for the development of this paper. Suggestions for improvements by reviewers were much
appreciated.

References
1. Code of Federal Register, 40 CFR 60.113b (a) (4) Testing and procedures.
2. Federal Register, Part II, 40 CFR Part 60: Proposed Rule and Notice of Public Hearing, 49 FR
29698, 1984.
3. U.S. EPA, Office of Air and Radiation, Emission Standards and Engineering Division, Research
Triangle Park, NC: VOC Emissions from Volatile Organic Liquid Storage Tanks – Background
Information for Promulgated Standards, EPA-450/3-81-003b, p. 2-48, 1987.
4. Quinn, D.M., Robotics Reduce Costs. Hydrocarbon Engineering, pp., 55-57, 2002.
5. Ibid.
6. ExxonMobil Seal Inspections, Draft Document to EPA on Remotely Controlled Aboveground
Storage Tank Primary and Secondary Seal Inspection Addressing 40 CFR Parts 60, 61, 63, and
65, 2003.
7. American Petroleum Institute, API technical Standard 653, Section 4.4.1.2 – Supplement, 1988.
8. ExxonMobil Seal Inspections, Draft Document to EPA on Remotely Controlled Aboveground
Storage Tank Primary and Secondary Seal Inspection Addressing 40 CFR Parts 60, 61, 63, and
65, 2003.
9. Ibid.
10. Ibid.
11. Ibid.
12. Quinn, D.M., InTANK, Primary and secondary seal inspections procedure presentation, 2003.

ENV-04-182
Page 14
13. Quinn, D.M., InTANK, and Mr. Vineet Masuraha, Consultant, Trinity Consultants, Discussion
on deck fittings inspection, 2003.
14. U.S. EPA, Office of Air and Radiation, Emission Standards and Engineering Division, Research
Triangle Park, NC: Alternative Control Techniques Document for Volatile Organic Liquid
Storage in Floating and Fixed Roof Tanks, EPA-453/R-94-001, pp., 5-6, 1994.
15. Hartsell, D.R., Advances in in-service robotics tank floor inspection systems for petroleum tanks,
Advanced AST Inspection, Management, and Protection Conference, pp., 5-6, 1999.
16. Manasia, D., U.S. EPA Region II Air Compliance Branch, a letter to Mr. Dale Pennington of
InTANK, Inc., Regarding robotic inspection of hazardous facility, March 31, 2003.
17. Whitley, G.M., Regional Air Quality Supervisor, NC DENR, a letter to Mr. Jeffrey D. Titus,
Colonial Pipeline Company, Regarding alternative gasoline tank inspection methods,
September 2, 2003.

About The Authors

Vineet K. Masuraha (corresponding author - vmasurah@trinityconsultants.com) is a Consultant and
Stacy Carr is a Senior Consultant (scarr@trinityconsultants.com) at Trinity Consultants, 12801 North
Central Expressway, Suite 1200, Dallas, TX 75243. Mr. Masuraha and Ms. Carr both provide
specialty-consulting services, including NSPS, Maximum Achievable Control Technology (MACT),
and New Source Review (NSR) permitting issues, to oil and gas (upstream and downstream) clients.

Mr. Masuraha's experience includes emissions and control strategies, compliance management
systems, regulatory and feasibility analyses, ambient air dispersion modeling and monitoring, and
state and federal air quality permitting. Ms. Carr’s experience includes permitting, compliance
auditing, training, emissions inventories, regulatory compliance analyses, regulatory impact
evaluation, and compliance management.

ENV-04-182
Page 15