Nelson Words

FOUNDATION

1. The perimeter of the tank bottom has edge settlement up to a 1.32-inch

drop over a 1-foot distance from the shell. The B/R ratio is 1.32
inches per foot, which exceeds the API allowable of 0.37 inch per foot
(Ref. API 653, Para. B.3.3). Since the shell-to-bottom joint was
examined by Magnetic Particle (MT), Vacuum Box (LT/BT) and Visual
Testing (VT) inspection methods and no recordable indications were
found, no corrective action is required. The edge settlement should be
re-evaluated at the next inspection interval.
2. The perimeter of the tank bottom has edge settlement up to a 4.68-inch
drop over a 3.33-foot distance from the shell. The B/R ratio is 1.41
inches per foot, which exceeds the API allowable of 0.37 inch per foot
(Ref. API 653, Para. B.3.3). Since the shell-to-bottom joint is coated
additional NDE examinations could not be performed. The extent of
the settlement warrants foundation repair or a more detailed analysis
should be performed.
3. Normally, differential settlement is a good indicator of settlement related
to foundation problems. In this instance, the tank rests on a concrete
slab with no evidence of cracks or significant misalignment due to
original construction (i.e. no cold joint). Since the tank is small in
diameter, the short arc distance between settlement readings results in
a very small allowable settlement per API 653 calculation. Because
this tank is on a stable slab, no corrective action or further evaluation
of settlement is necessary at this time.
4. The tank rests on a raised sand pad with an asphalt coating. The asphalt
berm has been severely broken up, creating voids around the tank.
The grade should be re-worked and these voids should be filled with
homogenous material to provide adequate drainage away from the
tank to allow for visual inspection of the shell-to-bottom joint area at all
times (Ref. API 653, Para. 4.3.1).
5. The concrete ring has severe damage at two (2) locations, Stations 16 ft.
and 212 ft. (measured CCW from Manway A). These cracks should
be further investigated to determine their depth and the ringwall
should be checked as to whether reinforcement is present and as to its
condition. The cracks should then be repaired to minimize further
degradation of the foundation.
6. The tank is resting on a concrete ringwall foundation. This ringwall has
cracks intermittently around the tank. These cracks should be sealed
to prevent further degradation of the foundation from moisture
penetration corroding the reinforcement or from freeze/thaw cycling
further opening these cracks.

Nelson Words

FOUNDATION

7. This ringwall has minor cracks intermittently around the tank. These
cracks should be sealed to minimize further degradation of the
foundation from moisture penetration corroding the reinforcement or
from freeze/thaw cycling further opening these cracks.
8. The tank is resting on a concrete ringwall foundation. This ringwall has
hairline cracks intermittently around the tank. The ringwall is coated
and this coating has failed. Consideration should be given to recoating the ringwall to minimize further degradation of the foundation
from moisture penetration corroding the reinforcement or from
freeze/thaw cycling further opening these cracks.
9. The tank is resting on a concrete ringwall foundation. This ringwall has
severe spalling and cracks intermittently around the tank. These
areas should be repaired and sealed to minimize further degradation
of the foundation from moisture penetration corroding the
reinforcement or from freeze/thaw cycling further opening these
cracks.
10. The grade surrounding the tank does not provide drainage away from the
foundation. Vegetation around the foundation and from under tank is
heavy. Consideration should be given to re-working the grade to
provide adequate drainage away from the tank and to allow for visual
inspection of the shell-to-bottom joint area at all times (Ref. API 653,
Para. 4.3.1).
11. The grade around the perimeter of the tank has washed away creating
voids under the shell and bottom edge projection. This condition
should be corrected by the addition of suitable subgrade material to
the periphery of the tank and under the shell-to-bottom projection.
(Precautions should be taken to avoid placing rock or gravel under the
tank since the presence of such material may result in increased
underside pitting corrosion).
12. At the time of inspection, the lower 0.5 to 1.0 inch of the shell was
covered with rock and soil from Stations 186.0 to 222.0 feet
(measured circumferentially CCW from Manway A). This area has
active corrosion on the shell and the bottom edge projection.
Consideration should be given to re-working this area to provide
adequate drainage away from the tank to allow for visual inspection of
the shell-to-bottom joint area at all times (Ref. API 653, Para. 4.3.1).
This area should be re-coated to minimize further corrosion.
13. There is no moisture barrier in place at the bottom edge projection,
allowing water to enter under the tank bottom. A suitable moisture
barrier should be installed around the entire tank bottom perimeter.

Nelson Words

BOTTOM

Twenty-eight (28) areas of underside corrosion with a remaining

thickness at or below 0.180 inch were found. Seven (7) areas of
internal corrosion with a pit depth of 0.070 inch or greater were found.
Thirty-four (34) holes were also found as a result of internal corrosion.
Patch plates should be fabricated and installed by lap welding. Areas
to be repaired should be ground smooth and minimum 12-inch x 0.25inch carbon steel patch plates should be installed over each area
using approved weld procedures per API 653 guidelines. Vacuum Box
Testing (LT/BT) should be performed on the patch plate weld seams.
Consideration should be given to improving top side or underside
corrosion protection by application of a coating or installation of a
cathodic protection system.
14. Exceptions to this are the three (3) areas of underside corrosion and one
(1) area of internal corrosion that lie in the critical zone. The
recommended repair for this widely scattered pitting (Ref. API 653,
Para. 7.9.1.1) should be by welding bottom patches (Revision to API
653, per Addendum 3, now allows bottom patches in the critical zone Ref. Para. 7.10.1.2 and Fig. 7-5).
15. Exceptions to this are the seven (7) holes and one hundred one (101)
areas of internal plate and weld corrosion that lie in the critical zone.
Due to the combination of internal corrosion and severe corrosion of
the bottom-to-shell weld, the recommended repair would be to install
new sketch plates around the entire base of the tank in accordance
with API 653 guidelines. Due to the extent of the corrosion found in
these areas, weld repairs within the critical zone would exceed API
653 guidelines. Consideration should be given to improving top side or
underside corrosion protection by application of a coating or
installation of a cathodic protection system.
16. The MFE floorscan revealed no areas of significant metal loss. There is
general internal corrosion throughout the tank averaging 0.010 to
0.020 inch, with a maximum depth of 0.040 inch. Based on these
findings, the next internal inspection should be conducted within 20
years if no repairs are made or no coatings are applied to the bottom
at this time.
17. The bottom is coated with an irregular fiberglass coating. Due to this
irregular coating, the MFE and UT examination of the bottom could not
be performed. The coating is in acceptable condition. Nominal bottom
thickness is 0.250 inch, which was verified at the bottom edge
projection outside.
18. The MFE and visual inspection of the tank bottom revealed over one
thousand (1,000) areas of internal pitting and severe general internal
corrosion. The shell-to-bottom weld has severe corrosion over 75% of

Nelson Words

BOTTOM

the total perimeter. There are several sketch plates that have pitting
within the critical zone that cannot be considered widely scattered.
This tank is a good candidate for a complete bottom replacement.
19. Corrosion rate calculations per API Standard 653, Para. 2.4.7 regarding
minimum tank bottom plate thickness based on the original date of
construction and the results of the inspection measurements by
ultrasonic readings, taken at random locations and at several areas of
one square foot automated scans, indicate a future service cycle
recommendation of 20 years is possible but it should be noted that
areas of the floor not inspected (especially bottom plate underside
areas not visible) could have actual corrosion rates which would
exceed those calculated from the information taken. On that basis,
consideration should be given to planning at least one additional
internal inspection at an intermediate interval to the 20-year calculated
cycle to confirm these corrosion rates or to establish new ones from
more complete or more recent data.
20. Based on these findings, the next internal inspection should be conducted
within 20 years subject to intermediate confirmation of continuing
coating integrity (tank should be cleaned and inspected for evidence
of internal corrosion or paint failure).
21. There are numerous pre-existing lap welded patch plates in the critical
zone which do not intersect the shell-to-bottom weld at ninety degrees
as recommended by API 653. This can result in areas of increased
stress concentration and possible accelerated corrosion. Visual
inspection did not identify any such corrosion present. Additional
inspection by Magnetic Particle (MT) methods indicated no identifiable
defects.
22. The roof support columns are welded to bearing plates that are welded to
the bottom. This detail results in the roof being rigidly connected to the
bottom. This practice is not recommended and these details should be
changed at the time the new bottom is installed.
23. The roof support pipe columns are welded to their base plates and these
base plates are not seal welded to the bottom. Consideration should
be given to changing this detail by detaching the pipe columns from
their base plates, installing lateral clips and seal welding the base
plates to the bottom.
24. The center roof support column clips do not provide adequate lateral
restraint from movement. Lateral clips should be installed to restrict
lateral movement in all directions.

Nelson Words

BOTTOM

25. The existing bottom edge projection from Stations 273.0 to 286.0 feet is
less than the 3/8 inch allowable per API 653, Para. 2.4.7.7. The
sketch plates affected by this condition should be replaced with
material having sufficient edge projection the next time this tank is
scheduled for major repairs to the shell or when a hydrotest is required
due to other repairs.
26. Eight (8) of the sixteen (16) floating roof striker plates exhibit numerous
areas of weld corrosion and product weeping from beneath. These
conditions should be repaired prior to returning the tank to service.
27. There are several areas of evidence of leakage from the bottom around
the tank. This riveted bottom is lined with a heavy irregular fiberglass
coating that extends up the shell. The lower six (6) inches of the shell
and rivets on the outside of the tank are severely corroded under
layers of epoxy coating. Due to the heavy irregular bottom coating,
the MFE and ultrasonic examination of the bottom plates could not be
performed. Visual (VT) inspection of the shell-to-bottom connection
was also impossible due to this heavy coating. This bottom should be
replaced with a new lap welded bottom installed through slots in the
shell cut above the corrosion or the coating could be removed to allow
for more complete bottom inspection.
28. Two leak paths were found on the bottom, one located on a plate-to-plate
lap weld and the other on the center roof support bearing plate seal
weld. These areas should be repaired in accordance with API 653
prior to returning the tank to service.
29. The ladder/gauge pole assembly is welded to its bearing plate and this
bearing plate is not seal welded to the bottom. The bearing plate is
restricted from movement with lateral clips welded to the bottom. A
better detail would be to seal weld the bearing plate to the bottom,
detach the ladder from the plate and relocate the lateral clips to
restrict the ladder/gauge pole movement.
30. There are two (2) pre-existing lap welded patch plates in the critical zone
on Plate 105 which do not intersect the shell-to-bottom weld at ninety
degrees as recommended by API 653. This can result in areas of
increased stress concentration and possible accelerated corrosion.
Visual (VT) inspection did not identify any such corrosion present.
Additional inspection by Magnetic Particle (MT) methods indicated no
identifiable defects.
31. Two leak paths were found in the shell-to-bottom weld on Plates 3 and 23.
These leak paths should be repaired in accordance with API 653. The
visual examination of the shell-to-bottom joint was limited due to poor
cleaning.

Nelson Words

BOTTOM

32. The tank currently has four (4) water draw nozzles with no draw-off
sumps. Consideration should be given to installing draw-off sumps in
the bottom at these locations so that water may be more effectively
removed from the tank. The draw-off sumps should be installed in
accordance with API 650 and 653 guidelines (Ref. API 650, Figure 318 and Table 3-16).
33. The tank currently does not have cathodic protection. Consideration
should be given to installing a cathodic protection system as a method
of achieving better corrosion control (Ref. API 651, Cathodic
Protection of Aboveground Petroleum Storage Tanks).
34. The center roof support column lateral clips do not provide adequate
restraint from movement. Consideration should be given to modifying
the clips so that lateral movement will be restrained.
35. The shell-to-bottom weld has severe crevice corrosion and the sketch
plates have deformed due to the edge settlement around the perimeter
of the tank. Note the examination of the sketch plates was limited due
to the edge settlement. The shell-to-bottom weld is covered with an
epoxy coating thus preventing a complete examination. Consideration
should be given to replacing the sketch plates to correct these
conditions or the coating should be removed to allow for more
complete inspection of these areas.
36. The roof support pipe columns do not have drainage holes at their base.
Drainage holes should be installed at the base of these pipe columns
to provide positive drainage.
37. The bottom edge projection has severe corrosion around the entire
perimeter of the tank with areas of complete deterioration. This
corrosion does not appear to extend beyond the shell-to-bottom weld.
Due to severe internal corrosion within the critical zone and edge
settlement, the recommended repair would be to install a new annular
plate ring around the entire base of the tank in accordance with API
653. Consideration should be given to improving the top side or
underside corrosion protection by application of a coating or by
installation of a cathodic protection system.

Nelson Words

SHELL

The tank does not have a ground system. Consideration should be

given to whether or not the tank is adequately grounded (Ref. API RP
2003 for additional guidance).
38. There are two (2) vertical welds that exhibit product leakage located on
Course 4 at Station 142.9 feet and on Course 3 at Station 173.4 feet
(measured circumferentially CCW from Manway A).
Further
investigation of these two (2) areas should be performed to identify the
cause of the leakage.
39. The shell has a band of corrosion up to six (6) inches from the shell-tobottom weld intermittently around the entire tank. The maximum depth
of this corrosion measured approximately 0.4 inch. Consideration
should be given to slotting the shell above this band of corrosion when
the tank bottom is replaced.
40. There are ten (10) holes equally spaced around the shell 27 inches below
the top of the tank. The holes are 1.5 inches in diameter and were
installed to provide visual confirmation of tank overfilling.
A
mechanical shield and screen should be installed over these openings
to prevent water and birds from entering the tank.
41. The shell has thirty (30) vents with rain hoods evenly spaced around the
top course. These vents do not have screens covering them to
prevent birds from entering the tank. The installation of screening over
these vents should be performed.
42. There are two (2) riveted door sheets located at Station 38.1 and Station
226.9 feet (measured circumferentially CCW from Manway A). There
is evidence of leakage at both locations on the outside of the tank.
This riveted door sheet is an API Appendix A shell connection which is
not normally used in tanks built to more current industry practices.
Consideration should be given to replacing this shell connection with
an API flush-type cleanout connection.
43. There are four (4) holes equally spaced around the shell 24 inches below
the top of the tank. The holes are 1.5 inches in diameter and were
installed to provide visual confirmation of tank overfilling.
Consideration should be given installing a mechanical shield and
screen to prevent water and birds from entering the tank.
44. Shell thickness calculations indicate the safe fill height of 48.00 feet can
be utilized with any product specific gravity up to 0.98. The
hydrostatic test height, or storage of any product with a specific gravity
between 0.98 and 1.0, should be restricted to between 48.00 and
47.18 feet, respectively (Ref. API 653, Para. 2.3.3.1).

Nelson Words

SHELL

45. There is a riveted door sheet located at Station 121.5 feet (measured
circumferentially CCW from Manway A). This riveted door sheet is an
API Appendix A shell connection which is not normally used in tanks
built to more current industry practices. Consideration should be given
to replacing this shell connection with an API flush-type cleanout
connection if there is long-term concern about the possibility of leaking
rivets.
46. Item K is a 5-inch diameter butt welded shell insert plate. This insert plate
does not meet API 653 minimum size requirements. This insert plate
should be replaced with one that meets API 653 requirements the next
this tank is scheduled for major repairs.
47. The bottom edge projection has leafing-type corrosion and coating failure
intermittently around the tank periphery. This area should be properly
cleaned to determine the extent of the corrosion and then re-coated to
minimize further corrosion.
48. The shell-to-bottom joint and bottom edge projection area has coating
failure around the entire periphery as well as active leafing-type
corrosion of the bottom edge projection. This area should be
completely sandblasted and re-coated.
49. Item L is a 5-inch x 0.25-inch lap welded patch plate. The lap patch
should be removed and a butt welded insert plate installed according
to current API standards (minimum 6-inch patch size required) the next
time welded repairs to the shell are performed.
50. The tank nameplate mounting bracket is not attached to the tank. This
nameplate should be permanently re-attached to the tank.
51. Due to the extended time this tank has been out of service, a full height
hydrostatic test is recommended prior to returning the tank to service.

Nelson Words

NOZZLES

Nozzles A, B, E, G, H and S have a weld spacing between their

reinforcing plates and the shell-to-bottom joint less than that required
by API 650, Para. 3.7.3. Nozzle F has a weld spacing between the
nozzle neck and shell-to-bottom joint less than that required by API
650, Para. 3.7.3. Nozzle D has a weld spacing from the nozzle neck
to the adjacent vertical weld less than that required by API 650, Para.
3.7.3. Such practices result in areas of increased stress concentration
and possible accelerated corrosion. Visual (VT) inspection of these
nozzles did not identify any such corrosion at this time. Additional
inspection by Magnetic Particle (MT) methods should be performed
(was performed and no identifiable defects were found).
52. Nozzles B and E have a weld spacing between their reinforcing plates
and the shell-to-bottom joint less than that required by API 650, Para.
3.7.3. Nozzles T and U have a weld spacing from their nozzle necks
to the shell-to-bottom weld less than that required by API 650, Para.
3.7.3. These nozzles should be raised in accordance with API 653,
Para. 7.8 at the time the bottom is replaced. Nozzles B to E and E to
F have a weld spacing between their reinforcing plates less than that
required by API 650, Para. 3.7.3. Item G covers twelve (12) sample
spigots that have a weld space between their necks less than that
required by API 650, Para. 3.7.3. Such practices result in areas of
increased stress concentration and possible accelerated corrosion.
Visual (VT) inspection did not identify any such corrosion at this time.
Additional inspection by Magnetic Particle (MT) methods should be
performed (was performed and no identifiable defects were found).
53. Nozzles A, D, F, H, J and K have a weld spacing between their reinforcing
plates and the shell-to-bottom joint less than that required by API 650,
Para. 3.7.3. Such practice results in areas of increased stress
concentration and possible accelerated corrosion.
Visual (VT)
inspection of these nozzles did not identify any such corrosion at this
time. Additional inspection by Magnetic Particle (MT) methods should
be performed (was performed and no identifiable defects were found).
54. Nozzles A, C, D, E, I, O, Q, S and U have a weld spacing between their
reinforcing plates and the shell-to-bottom joint less than that required
by API 650, Para. 3.7.3.
55. Nozzles N & O and Q & S have a weld spacing between their reinforcing
plates less than that required by API 650, Para. 3.7.3.
56. Nozzles C and D have a common reinforcing plate that is welded directly
over a vertical weld. API 650 currently allows this practice subject to
additional non-destructive examination. This detail has been present
for an extended period and visual inspection found no identifiable
defects.
57. Nozzles Q & R, R & S and V & W have a weld spacing between the
reinforcing plates and nozzle necks less than that required by API 650,
Para. 3.7.3.

Nelson Words

NOZZLES

58. Nozzles O to N and F to G have a weld spacing from their reinforcing

plate to nozzle neck weld less than that required by API 650, Para.
3.7.3.
59. Item L covers twelve (12) sample spigots that have weld space between
their necks less than that required by API 650, Para. 3.7.3.
60. Nozzles G to H, H to J, J to K, K to M and M to N have a weld spacing
between their necks less than that required by API 650, Para. 3.7.3.
Such practices result in areas of increased stress concentration and
possible accelerated corrosion. Visual (VT) inspection did not identify
any such corrosion at this time. Additional inspection by Magnetic
Particle (MT) methods should be performed (was performed and no
identifiable defects were found).
61. Nozzles B, C, H, J and K have a weld spacing between their reinforcing
plates and the shell-to-bottom joint less than that required by API 650,
Para. 3.7.3. Nozzles D and F have a weld spacing between their
reinforcing plates less than that required by API 650, Para. 3.7.3.
Nozzle J has a weld spacing from the reinforcing plate to the adjacent
vertical weld less than that required by API 650, Para. 3.7.3. These
nozzles should be raised in accordance with API 653, Para. 7.8 if the
bottom is replaced and the shell is slotted.
62. Nozzles A, J, T and AA have a weld spacing between their reinforcing
plates and the shell-to-bottom joint less than that required by API 650,
Para. 3.7.3.1. The weld spacing between the reinforcing plate of
Nozzle T and the adjacent vertical weld is less than that required by
API 650, Para. 3.7.3.1. Such practices result in areas of increased
stress concentration and possible accelerated corrosion. Visual (VT)
inspection did not identify any such corrosion at this time. Additional
inspection by Magnetic Particle (MT) methods should be performed
(was performed and no identifiable defects were found).
63. The weld spacing between the neck of Nozzle F to the reinforcing plate of
Nozzle G is less than that required by API 650, Para. 3.7.3. Nozzle O
has a weld spacing from its neck to the adjacent vertical shell weld
less than that required by API 650, Para. 3.7.3. Such practices result
in areas of increased stress concentration and possible accelerated
corrosion. Visual (VT) inspection did not identify any such corrosion at
this time. Additional inspection by Magnetic Particle (MT) methods
should be performed (was performed and no identifiable defects were
found).
64.

Item Y is a square-cornered door sheet not coincident with the nearest

shell horizontal weld seams. API 653, Figure 7-1 suggests that
replacement shell plates should have rounded corners with a minimum
radius of curvature of Dr /2. The corner areas should be further
inspected by Magnetic Particle (MT) methods to determine if any

Nelson Words

NOZZLES

identifiable defects are present (was inspected and no identifiable

defects were found) and these areas should be monitored in future for
signs of stress concentrations.
65. Nozzle U has a split reinforcing plate with only one telltale hole. API 650,
Paras. 3.7.5.1 and 3.7.6.1 indicate reinforcing plates or each segment
of the plates if they are not made in one piece should be installed with
telltale holes. A telltale hole should be drilled and the space behind the
reinforcing plate verified as gas-free prior to any future hot work on
this nozzle detail in case any undetected product has leaked into this
area.
66. Nozzle J has a reinforcing plate without a telltale hole. API 650, Paras.
3.7.5.1 and 3.7.6.1 indicate reinforcing plates should be installed with
telltale holes. A telltale hole should be drilled and the space behind the
reinforcing plate verified as gas-free prior to any future hot work on
this nozzle in case any undetected product has leaked into this area.
The telltale hole should then be left open to the atmosphere.
67. Nozzles J and K have reinforcing plates without telltale holes. API 650,
Paras. 3.7.5.1 and 3.7.6.1 indicate reinforcing plates should be
installed with telltale holes. Telltale holes should be drilled and the
space behind each reinforcing plate verified to be gas-free prior to any
future hot work on these nozzles in case any undetected product has
leaked into this area. The telltale holes should then be left open to the
atmosphere.
68. Nozzles A, B, C, E, F, G, J and K have telltale holes that are plugged. API
650, Paras. 3.7.5.1 and 3.7.6.1 indicate reinforcing plates should be
installed with telltale holes left open to the atmosphere. These plugs
should be removed prior to returning the tank to service. The telltale
holes should then be left open to the atmosphere.
69. Nozzle A has a telltale hole that is plugged. API 650, Paras. 3.7.5.1 and
3.7.6.1 indicate reinforcing plates should be installed with telltale
holes left open to the atmosphere. This plug should be removed prior
to returning the tank to service. The telltale hole should then be left
open to the atmosphere.
70. The internal neck-to-shell weld on Nozzles I and J shows signs of weld
corrosion and product stains indicating a leak path. These nozzles
should be weld repaired in accordance with API 653.
71. Nozzle J does not have a reinforcing plate as suggested by API 650,
Para. 3.7.2.1 which states that, Openings in tank shells larger than
required to accommodate a NPS 2 flanged or threaded nozzle shall be
reinforced. Consideration should be given to installing a reinforcing

Nelson Words

NOZZLES

plate around this nozzle neck at the next opportunity when welding
repairs to the shell are to be performed.
72. Nozzle F has its valve welded directly to the shell. This is not an API
standard connection detail. This connection should be replaced with
an API standard shell nozzle detail the next time this tank is scheduled
for major repairs to the shell or when a hydrotest is required due to
other repairs.
73. The water draw Nozzle H is a 4-inch threaded nozzle with a 6-inch
opening cut in the shell. This is not an API standard detail and is not a
recommended practice. This nozzle should be replaced with an API
standard nozzle detail (per API 650, Fig. 3-5) the next time this tank is
scheduled for major repairs to the shell.
74. The nominal neck thickness of Nozzles A, B, C has been reduced as a
result of service conditions over the life of the item. Consideration
should be given to performing further evaluation to determine whether
or not the nozzle neck is suitable for continued service without repair
or replacement (Note to API Inspector/Technical Report Writer - from a
practical standpoint, we should record in the field and include in the
report Summary any neck thickness more than 10% less than the
nominal thickness. This assumes that the neck was either Sch. 80 or
X-strong wall thickness to begin with).
75. The neck thickness of Nozzle G indicates that the nozzle neck is less
than the minimum required per API 650, Table 3-6, Column 3. These
details have been present for an extended period of time and no
immediate corrective action is required. Consideration should be given to
further evaluation to determine whether or not the nozzle neck is suitable
for continued service without repair or replacement, or to modifying these
details as necessary at a future opportunity when welded repairs to the
tank are planned.
The neck thickness of Nozzles G, L, P, and R indicates that the nozzle necks
are less than the minimum required per API 650, Table 3-6, Column 3. These
details have been present for an extended period of time and no immediate
corrective action is required. Consideration should be given to further
evaluation to determine whether or not the nozzle necks are suitable for
continued service without repair or replacement, or to modifying these details
as necessary at a future opportunity when welded repairs to the tank are
planned.
1.

Nelson Words

NOZZLES

The neck thickness of Nozzle J-1 does not meet the minimum
requirements of API 650, Table 3-6, Column 3. Consideration should be
given to replacing this nozzle with details that meet minimum API 650
nozzle requirements (ref. Fig. 3-5).

1. The neck thickness of Nozzles A, B, C. indicates that the nozzle neck is

less than Sch. 80 or X-strong thickness required by API standards of
construction. These details have been present for an extended period
of time and no immediate corrective action is required. Consideration
should be given to further evaluation to determine whether or not the
nozzle neck is suitable for continued service without repair or
replacement, or to modifying these details as necessary at a future
opportunity when welded repairs to the tank are planned (Note to API
Inspector/Technical Report Writer - this situation should be noted in
the inspection checklist and this comment used in the report Summary
whenever it is evident from UT readings that the nozzle neck does not
meet minimum API 650 neck thickness requirements from original
construction or later modification).
2. Nozzles A, B, E, F, and H have reinforcing plates that do not meet the
minimum size requirements of API 650 (Ref. Table 3-6, Columns 5 and
6). These nozzles should be replaced with API standard nozzle details
the next time this tank is scheduled for major repairs to the shell.(IRD)
3. Nozzles A, B, E, F, and H have reinforcing plates that do not meet the
minimum thickness requirements of API 650 (Ref. Table 3-7, Column
1). These nozzles should be replaced with API standard nozzle details
the next time this tank is scheduled for major repairs to the shell. (IRT)
4. Nozzle G is a manway with a six-inch product suction line penetrating its
cover. This detail (withdrawal line through manway cover plate) is not
a common practice. Consideration should be given to replacing this
detail with a standard API shell nozzle penetration the next time this
tank is scheduled for major repairs.
5. There is a riveted door sheet located at Station 123.0 feet (measured
circumferentially CCW from Manway A). This riveted door sheet is an
API Appendix A shell connection which is not normally used in tanks
built to more current industry standards. Consideration should be
given to replacing this shell connection with an API flush-type cleanout
connection.
6. Nozzle F is a blind flange that has thread engagement less than flush on
several bolts. This bolting detail should be replaced with studs of
sufficient length to provide at least one thread per stud extending past
the nut.

Nelson Words

NOZZLES

7. Nozzles D and J are 10-inch product lines with 16-inch openings cut in
the shell. This results in the nozzle neck being welded to the
reinforcing plate but not to the shell. The size of the reinforcing plate
is also less than required for this size shell opening. These are not
API standard details and are not recommended practices. These
nozzles should be replaced with API standard nozzle details (per API
650, Fig. 3-5) the next time this tank is scheduled for major repairs to
the shell.
8. The water draw Nozzles E, I and S are threaded nozzles. Consideration
should be given to replacing these nozzles with API 650 flanged
nozzle details per Figure 3-5.
9. Nozzles B, D, E and F are 3-inch threaded water draw nozzles.
Consideration should be given to replacing these nozzles with new
API flanged nozzle details at a future opportunity when the tank is
taken out of service for welded shell repairs.
10. Nozzle I is a 3-inch nozzle installed offset into a 5-inch shell opening with
very poor quality welding between the nozzle, shell and reinforcing
plate. This nozzle should be replaced with an API standard nozzle
detail (per API 650, Fig. 3-5) at a future opportunity when welded
repairs to the shell are performed.
11. Nozzles D and Q have their valve bodies welded directly to the shell.
This is not an API standard detail. These connections should be
replaced with API standard shell nozzle details the next time this tank
is scheduled for welding repairs to the tank shell or when a hydrotest
is scheduled for other repairs.
12. Nozzle J appears to have been installed by hot tapping. This nozzle
should have the sharp edges removed and the inside neck-to-shell
detail should be seal welded.
13. The tank gauge and high level alarm systems should be tested, repaired if
necessary and calibrated prior to returning the tank to service.
14. The tank ground system has two (2) locations with no ground cable or
rod. A ground cable and rod should be properly installed at these
locations prior to returning the tank to service if it is determined that
additional tank grounding is required.
15. Nozzle N (the roof drain) is bolted to its reinforcing plate. This is not an
API standard detail and should be replaced with a welded API flanged
nozzle detail.

Nelson Words

NOZZLES

16. The tank currently does not have a high level alarm. Consideration
should be given to installing a high level alarm system or alternative
overfill protection device prior to returning the tank to service.
17. The reinforcing pad for Nozzle K is welded over a vertical seam. This
practice also presents risks of accelerated corrosion and stress
concentration. API 650 currently allows this practice subject to
additional non-destructive examination. This detail has been present
for an extended period of time and Visual (VT) inspection found no
identifiable defects. The nozzle detail should be monitored in future.
18.

Nozzles A, B, C, D, N, Q, R, T and X have square-cornered reinforcing

plates. API 650, Figure 3-5 suggests that reinforcing plates should
have rounded corners with a minimum radius of curvature of D r /2.
These details have been present for an extended period of time and
no immediate corrective action is required. Consideration should be
given to replacing these reinforcing plates with API standard detail
plates at a future opportunity when other welding repairs to the shell
are planned.

19. The tank ground system has three (3) locations with improper
connections. Item J located at Station 96.8 feet is not attached at the
rod. Item M located at Station 154.4 feet, the rod is pulled out of the
ground and laying on the surface. Item Y located at Station 333.7 feet
is not attached at the shell.
All locations are measured
circumferentially CCW from Manway A. Consideration should be given
to further evaluating the need for grounding of this tank (reference API
2003 for additional guidance).
20. There is an attachment weld failure on the stairway between Treads 28
and 29. These attachment welds should be repaired before the tank is
returned to service or use of the stairway restricted due to personnel
safety concerns.
21. Nozzles C and F were installed by hot tapping. These nozzles should be
have the sharp edges removed and each inside neck-to-shell detail
should be seal welded.
22. Nozzles J and K are 10-inch nozzles with a 14.5-inch hole cut in the shell
resulting in the nozzle being welded to the reinforcing plate. This is
not a standard API nozzle detail and is not a recommended practice.
Consideration should be given to replacing this nozzle detail with a
standard API nozzle connection detail at a future opportunity where
welded repairs to the shell are to be performed.
23. Nozzle D is a blind flange that has thread engagement less than flush on
several bolts. This nozzle has a plugged telltale hole and seepage

Nelson Words

NOZZLES

from a hole within the seal weld on the internal side. Consideration
should be given to replacing the bolting with studs of sufficient length
to provide at least one thread extending past the nut on each stud and
to repairing the internal seal weld and pressure testing the reinforcing
plate.
24. Nozzle Q was installed by hot tapping and the trough on the inside of the
tank is only partially welded to the shell. This nozzle is not in service.
It is blinded on the outside of the tank and does not currently have
external connecting piping. The reinforcing plate on this nozzle does
not have rounded corners or a telltale hole. Consideration should be
given to carefully removing the trough from the shell grinding the
sharp edges and possibly seal welding this nozzle on the inside, but
only after a telltale hole is drilled in the reinforcing plate outside and
the space is verified to be gas-free before any hot work is performed.
25. Nozzle H does not have an adequate reinforcement plate in accordance
with API 650. This nozzle should have its reinforcement plate
replaced using an API standard detail at a future opportunity when
welding repairs to the tank shell are to be performed.
26. Nozzles D and K have evidence of leakage around the valve stems. The
valve packing should be replaced on these nozzles valves prior to
returning the tank to service.
27. The water draw line piping support welds at the support to the pipe, near
the shell, are cracked. These welds should be repaired or the support
detail should be changed to one providing more flexibility of future
movement.
28. Nozzles M, O and the RVP nozzle were installed by hot tapping. These
nozzles should have the sharp edges removed and seal welded on the
inside. These three (3) nozzles also have plugged telltale holes. After
completion of the repairs, the plugs should be removed and the telltale
holes left open.
29. Nozzle F appears to have been installed by the hot tap method. The
sharp edges remaining on the inside of the shell should be removed
and the nozzle seal welded on the inside.
30. Nozzles E and G have sharp edges and burrs on the inside of the shell.
These conditions should be corrected prior to returning the tank to
service.
31. Nozzles C and H both have their valves welded directly to the shell. This
is not an API standard detail and not a recommended practice. Both

Nelson Words

NOZZLES

nozzles should be replaced with an API standard shell nozzle detail at

a future opportunity when welded repairs to the shell are performed.
32. The attachment weld at Station 173.0 feet (measured circumferentially
CCW from Manway A) has a visual indication of possible weld defect.
The coating should be removed and a surface examination such as
Magnetic Particle (MT) or Liquid Penetrant (PT) performed to verify its
integrity.
33. There is an open area between the intermediate platform handrail and the
stairway handrail that is a safety concern. A safety chain or other
suitable device should be installed to eliminate this open area.
34. The shell penetration for the water draw (Nozzle G) is cut through an
existing insert plate. A Magnetic Particle (MT) examination was
performed on the penetration area and no indications were identified.
This nozzle should be monitored during future inspections.
35. The cathodic protection cable attachment to the shell located at Station
187.2 feet (measured circumferentially CCW from Manway A) is
detached.
Consideration should be given to re-attaching this
connection to the shell.
36. The tank gauge pole is supported by the bottom of the tank and is only
slotted up to a level even with the top of the second shell course. This
comment is supplied as information only.
37. Nozzle H is a six-inch threaded coupling that does not have a reinforcing
plate. This is not an API standard nozzle detail. Nozzle reinforcement
calculations indicate this nozzle does not provide adequate
reinforcement. Consideration should be given to replacing this nozzle
with an approved API standard detail nozzle design at a future
opportunity when welded repairs to the shell are to be performed.

Nelson Words

FIXED ROOF

Nozzles B, C and D are bolted to the roof to accommodate the Enraf

gauge and the high level alarm. Consideration should be given to
replacing these bolted nozzles with API 650 welded roof nozzle details
(Ref. Fig. 3-16) or appropriate measures should be taken to insure
that these details do not allow water to leak into the tank or product
vapor to escape out.
38. The fixed roof has three (3) six-inch pressure/vacuum vents that are
painted shut.
Consideration should be given to verifying the
requirement for these vents and for the cleaning, testing and
calibrating of them if they are required for tank operation.
39. The roof coating is failing near the frangible joint with areas of peeling,
rust-colored stains and corrosion. These areas should be sandblasted
and re-coated.
40. Nozzles A and B are bolted to the roof. Consideration should be given to
replacing these bolted details with welded API 650 roof nozzle details
(Ref. Figure 3-16) or appropriate measures taken to insure that these
details do not let water leak into the tank or product vapor to escape
out.
41. Nozzles B, C and D are bolted to the roof to accommodate the level
gauge, temperature instrumentation and the high level alarm.
Consideration should be given to replacing these bolted nozzles with
API detail welded roof nozzles or appropriate measures should be in
place to insure that these details do not allow water to leak into the
tank or product vapor to escape out.
42. Nozzle E is bolted to the roof to accommodate the
system. This bolted nozzle should be replaced with
roof nozzle detail (Ref. Figure 3-16) or appropriate
be in place to insure that this detail does not allow
the tank or product vapor to escape out.

high level alarm

a welded API 650
measures should
water to leak into

43. There is a safety rail extending to the center of the roof from the stairway
platform that is both bolted to the roof and to its attachment members.
Consideration should be given to replacing all bolted connections with
welded ones.
44. The flame arrestor should be cleaned, tested and calibrated to insure
proper operation.
45. There is one overflow located over the stairway. Consideration should be
given to either relocating this overflow or sealing it closed.

Nelson Words

FIXED ROOF

46. The mid-rail for the roof safety railing at the top of the stairway has a
failed weld. The attachment weld at the mid-rail should be repaired as
soon as possible to eliminate a possible personnel safety hazard.
47. There is a safety rail extending from the stairway platform railing to the
gauge support structure that is both bolted to the roof and to its
attachment members. Consideration should be given to replacing all
bolted connections with welded ones.
48. There are two (2) ten-inch pressure/vacuum vents with flame arrestors.
Consideration should be given to verifying they provide adequate
relief for the tank and to cleaning, testing and calibrating both units.
49. There is an old gauge access hatch that is bolted to the roof. This hatch
is missing three (3) bolts and allows water to enter the tank.
Consideration should be given to replacing this hatch with a seal
welded patch plate or appropriate measures should be taken to insure
that this detail does not allow water into the tank or product vapor to
escape out.
50. The roof has four (4) eight-inch vacuum breakers that are bolted
connections. Consideration should be given to determining the
requirement of these vents and either replacing them with welded
nozzles or removing them and seal welding patch plates on the roof. If
required for operation, appropriate measures should be taken to
insure that these details do not allow water into the tank or product
vapor to escape out. These vents should be cleaned and calibrated if
they are to remain in service.
51. The tank does not have a ladder from the fixed roof to the floating roof.
The gauge pole is an eight-inch aluminum pipe that is welded to the
tank bottom. Consideration should be given to replacing the gauge
pole with a combination gauge pole/ladder assembly to provide
access to the floating roof.
52. The hatch cover on the gauge pole is missing a hinge and is not attached
to the hatch. This condition should be corrected.
53. The roof center vent does not have a screen to prevent birds from
entering the tank. This vent should have a screen installed over the
opening.

Nelson Words

FLOATING ROOF

The floating roof seal is a foam log. This seal is soaked with product
and should be replaced prior to returning the tank to service.
54. Nozzle C, vacuum breaker, currently does not have a striker plate under
its leg. Consideration should be given to installing a seal welded
striker plate under the vacuum breaker leg.
55. The roof drain sump is full of debris. The sump and drain line should be
cleaned out to allow for proper drainage of the roof. The roof currently
is retaining a large amount of water around the center pontoon
chamber. This condition should be monitored after the roof is returned
to service to verify that the water properly drains away.
56. The grounding cable from the shell to the rolling ladder is not connected.
This cable connection should be repaired or replaced prior to returning
the tank to service.
57. The vacuum breakers have only one leg setting (low roof position) and
are blind-flanged, rendering them inoperable. The need for and
operability of the vacuum breakers should be evaluated and any
necessary modifications or repairs should be performed.
58. The primary seal is a mechanical shoe. The vapor barrier and the shoes
are severely deteriorated. A new primary seal should be installed prior
to returning the tank to service.
59. The floating roof seal has been removed. A new primary seal should be
installed prior to returning the tank to service.
60. The foam log primary seal was removed prior to the inspection. A new
primary seal is scheduled to be installed prior to returning the tank to
service.
61. The floating roof nozzle vapor gaskets and appurtenance vapor seals
should be replaced prior to returning the tank to service.
62. The mechanical vacuum breaker leg is not adjustable and will only
operate when the roof is in low position. Consideration should be
given to making the vacuum breaker leg adjustable (pin settings for
both high and low roof positions).
63. The floating roof was not accessible due to the unsafe condition of the
vertical ladder. Visual inspection of the seal from the underside of the
floating roof revealed no apparent defects. The vertical ladder should
be repaired if access via that means is ever anticipated or desired.

Nelson Words

FLOATING ROOF

64. The floating roof is a steel pan with legs in fixed low roof position which
was installed in 1972. This roof does not have a vacuum breaker.
65. The floating roof appurtenance vapor seals (i. e. vapor seal at the gauge
pole well or around column wells in internal floating roofs) should be
replaced prior to returning the tank to service.
66. The primary seal is a foam log. This seal has gaps of 0.5 inch to 1.25
inches for over 45% of the tank perimeter. This seal should be
repaired or completely replaced prior to returning the tank to service.
67. The primary seal mechanical shoes are severely corroded intermittently
around the tank. The primary seal shoes should be replaced prior to
returning the tank to service.
68. The mechanical vacuum breaker leg is not adjustable and will only
operate when the roof is in low position. Consideration should be
given to making the vacuum breaker leg adjustable.
69. The floating roof rim vent is not operable. This vent should be repaired to
allow for proper operation.
70. The rolling ladder platform is bolted to the roof. Consideration should be
given to replacing the bolted connections with welded details.
71. The floating roof appurtenance seals (i. e. vapor seal around gauge pole
well or at column wells in internal floating roofs) show signs of
deterioration and should be replaced prior to returning the tank to
service.
72. There are three (3) floating roof legs located on Plates 22, 31 and 37 that
are too short and do not provide support to the roof. There is also one
(1) leg missing on Plate 27. These conditions should be corrected
prior to any additional work being performed on or under the roof.
73. The mechanical vacuum breaker legs are not adjustable and will only
operate when the roof is in low position. Consideration should be
given to making the vacuum breaker legs adjustable so that they will
operate the vents with the roof in either low or high position.
74. Nozzles B and L are combination pressure/vacuum vents. Nozzle L also
has a flame arrestor. This tank has four roof vents and four shell vents
that were installed after original construction. Due to the additional
venting to the tank, Nozzles B and L may no longer be required for
tank operation. Consideration should be given to determining the
need for these vents and either removing them or cleaning, testing
and calibrating them prior to returning the tank to service.

Nelson Words

FLOATING ROOF

75. There are two (2) six-inch pressure/vacuum vents. These vents should be
cleaned, tested and calibrated prior to returning the tank to service.
76. The roof bolting securing the sheeting to the channels is severely
corroded. There is one area near the shell where the bolting is loose
and not securing the sheeting properly. Consideration should be
given to replacing this bolting with a non-corroding material.
77. The roof seal is an old style mechanical system that is worn and may not
have much service life remaining. The seal fabric was removed prior
to the inspection. Consideration should be given to replacing the old
mechanical seal system with a new design.
78. The rolling ladder is missing a handrail at the top on one side. The
support structure does not have a deck to step on to at the bottom of
the ladder. The ladder does not have self-leveling stairs. The rolling
ladder should be repaired to insure a safer and more operable
condition.
79. There are five (5) roof legs that do not rest on the tank bottom. The legs
are located on Plates 24, 48, 50, 69 and 70. These roof legs should
be modified/adjusted so that they provide adequate support for the
floating roof.
80. The roof coating system has failed and there is rust and corrosion on the
roof deck. Consideration should be given to sandblasting and recoating the roof deck.
81. The top of the pontoon roof deck has been sand blasted around the
outside perimeter following the removal of the seal material. This area
has scattered pitting with an average depth of 0.060 inch. This seal
should be replaced with a new system that will not retain product at
the rim and the roof re-coated to minimize further corrosion.
82. There are two (2) pontoons that have product inside the chambers on the
outside perimeter. These pontoons should be removed and replaced.
83. The roof drain sump is full of dirt and debris. Consideration should be
given to cleaning the sump and the drain line.
84. The floating roof is an aluminum pontoon. The roof has three (3) missing
legs, one (1) leg that is bent, thirty-nine (39) legs out of plumb and ten
(10) legs that are corroded and missing their feet. The roof is in severe
service due to the high velocity of product entering the tank, especially
near the diffuser line where pontoons were added to provide additional

Nelson Words

FLOATING ROOF

flotation. Consideration should be given to replacing this roof with one

that could better withstand the service presented by these conditions.
85. The inspection found two (2) grounding cables between the floating roof
and the shell that are no longer attached. These cables are to help
prevent the build-up of static electricity. Consideration should be
given to re-attaching these ground cables (shunts) from the floating
roof to the shell.
86. The floating roof has three (3) vacuum breakers that are currently not
operable. Two (2) vacuum breakers are missing one of the guide
vanes. All three (3) vacuum breakers are not pinned and would not
operate at the current roof position. Consideration should be given to
correcting these conditions before the tank is returned to service.
87. The rolling ladder is missing a handrail at the top on one side. There is
mechanical damage to the ladder and handrail midway down the
ladder and on the support structure at the base of the ladder. The
ladder runway does not have grating to step on to at the bottom of the
ladder. The ladder does not have self-leveling stairs. The rolling
ladder was sand blasted prior to the inspection. The rolling ladder
damage should be repaired to a safer and more operable condition
before the tank is returned to service.
88. The mechanical vacuum breaker leg is not adjustable and will only
operate when the roof is in low position. Consideration should be
given to making the vacuum breaker leg adjustable.
89. There are three (3) roof legs that do not rest on the tank bottom. The legs
are located on Plate numbers 36, 56 and 91. Consideration should be
given to adjusting or modifying the length of these roof legs so that
they provide adequate support for the floating roof.
90. There is one (1) vacuum breaker six (6) inches in diameter on the roof.
The leg of this vacuum breaker is bent preventing its proper operation
This vacuum breaker should be repaired prior to returning the tank to
service.
91. The floating roof rim vent is full of debris. This vent should be cleaned so
that its proper operation can be performed.
92. The roof drain is an old style pipe system. This drain system should be
cleaned and pressure tested to verify its integrity or completely
replaced with a new style system.
93. The roof drain line has failed on both the inside and outside of the tank.
There is currently a bolted clamp-on seal on the outside of the tank

Nelson Words

FLOATING ROOF

near the valve to prevent product leakage. This line is no longer used
to drain water from the roof due to the installation of a geodesic dome.
This line should be completely removed or isolated as soon as access
to the tank can be achieved. A close visual inspection and possible
Ultrasonic (UT) examination of the remaining piping should be
performed to verify its integrity or a pressure test should be performed
once the tank is emptied and before the tank is returned to service.
94. The roof is currently pinned in high position and there are only cotter pins
on one side of the roof leg pins. Consideration should be given to
installing cotter pins on both sides of the leg pins to keep them in
position.
95. The rolling ladder has two treads that have come off their pivot hinges
and one tread missing at the base of the ladder. These conditions
should be corrected before the tank is returned to service to allow
continued safe operation of the ladder.
96. The floating roof primary seal has deteriorated with large areas of the seal
missing and the secondary seal is starting to show signs of
deterioration. A new primary and secondary seal should be installed
prior to returning the tank to service.
97. The floating roof vacuum breaker legs are currently set for the low roof
position. The roof is currently set in high position, making the vacuum
breakers inoperable. The roof legs should be set to operate in low
roof position after returning the tank to service.
98. The pontoon support straps on the pontoons above Plates 41 and 89
have failed and the strap on the pontoon above Plate 5 is torn. These
straps should be replaced prior to returning the tank to service.
99. There are eighty-five (85) floating roof legs with no striker plates.
Consideration should be given to installing seal welded striker plates,
steel striker plates permanently affixed to the bottom by alternate
means (epoxy) or manufacturers aluminum leg pads (with pins) under
each roof leg.
100.There are two (2) twenty-inch combination pressure/vacuum vents on the
floating roof. Consideration should be given to cleaning, testing and
calibrating these vents.
101.The floating roof has six (6) legs that are not plumb on Plates 3, 8, 19,
21, 40 and 49. Consideration should be given to re-positioning these
roof legs.

Nelson Words

FLOATING ROOF

102.The two (2) gauge openings and the ladder opening on the floating roof
do not have vapor seals to prevent the escape of product vapors.
These penetrations should have vapor seals installed around their
openings to reduce the escape of product vapors.
103.There is a ten-inch vacuum breaker vent on the floating roof. This vent is
currently not operable due to the adjustment pin being removed. This
pin should be replaced at the proper setting prior to returning the tank
to service.
104.The floating roof has twenty-four (24) legs that are missing one (1) of
their cotter pins and two (2) legs that are missing both cotter pins that
help keep the leg pins in proper position. These cotter pins should be
replaced prior to returning the tank to service.
105.Safety Note: The access to the rolling ladder has been modified due to
the installation of the geodesic dome. The current access is not safe
due to the lack of steps from the platform to the rolling ladder. This
detail should be modified or changed to increase the personnel safety
at this access point.
106.The floating roof primary seal is a mechanical shoe. The vapor seal
material and shoes are starting to deteriorate with areas of severe
corrosion and holes. This seal should be replaced. The secondary
seal is a wiper. This seal is in acceptable condition.
107.The roof drain is an old style mechanical joint drain. There are several
areas of damage along the fixed piping. The useful remaining life of
this drain is limited and consideration should be given to replacing it
with a more modern system designed for better flow and reliability or
this drain should be pressure tested prior to returning the tank to
service.
108.The rolling ladder is missing a handrail at the top on one side. The
ladder does not have self- leveling stairs. The rolling ladder should be
repaired to a safe operating condition before the tank is returned to
service.

Nelson Words GEODESIC DOME

The dome attachment plate bolting to the roof near the rolling ladder is
loose and the plate is not normal to the attachment point.
Consideration should be given to correcting this condition.
109.There are four (4) areas of the bird screening that have fallen away from
the dome. Consideration should be given to replacing the screens.
110.There is visual evidence on the internal floating roof deck (water stains)
that the dome has leaks. The roof leaks should be repaired or the floating
roof drain system should be kept in operation.