Allentech reprint.

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HAZARDOUS CARGO BULLETIN May 2006

Hang in there
FLOATING ROOFS The introduction of cable suspension systems has taken aluminium internal floating roofs to a new level of safety. New technology and subsequent independent testing of bolted seams for certain full contact honeycomb roofs have also indicated significant reductions in emissions, as Allentechs Bill Grimes* explains
Safety is the first and highest priority to Allentech and to all the petrochemical companies we work for and are associated with. Although we have been performing this work for many years, entering a tank while in service to change leg settings is a risky procedure. And because it takes three well trained workers, equipped properly, it is a time-consuming and an expensive job. In order to enter a tank in service the internal floating roof (IFR), whether steel or aluminium, must be floating within fifteen feet of the top of the fixed roof and be dormant for at least two hours with all tank vents open to exhaust the contained vapours. The lower explosive limit (LEL) inside the tank within the space between the floating roof and the fixed roof must not be greater than 10 per cent, measured comprehensively. The worker entering the tank must wear a fall and rescue device (full body harness) connected via cable to a tripod with a rescue winch and fall protection device mounted over the manway on the fixed roof. He must be wearing a full face mask and Scott Air Pack or be connected to forced fresh air. The second worker, a dedicated standby, must be equipped with all of the same safety gear and fresh air equipment. The third worker, a second dedicated standby, must maintain contact with the worker in the tank and with the terminal via radio. The worker changing the leg settings enters the tank and walks all around the roof while it is floating on gasoline, ethanol or a similar product and removes or installs a bolt and nut, depending on the support leg design, changing the setting on all support legs. If a leg is inadvertently missed, the roof could be damaged when landed. Many petrochemical companies today simply will not allow inservice entries and all of them certainly want to avoid it because of the risk. Since most aluminium IFRs weigh less than two pounds per square foot, new tanks can be designed, and most existing tanks can be retrofitted to suspend the AIFR from the fixed roof. Suspending an AIFR by cable eliminates the need for conventional two position legs and produces multiple demonstrative benefits. From a safety point of view it allows the IFR position to be changed from the top of the fixed roof, eradicating the requirement to enter the tank while in service. It becomes a one-man, much lower risk job that can be accomplished in approximately four hours by a terminal operator rather than two days by a three-man crew of specially trained and

Allentechs honeycomb seal is at the heart of the system

fully equipped workers. Eliminating in-service entries to make leg changes is an enormous safety improvement. Another safety factor becomes apparent when personnel are in a tank, under a floating roof for cleaning, inspections and repairs. While in the process of writing this article, a fatal accident occurred in a Southern California refinery involving personnel working under a steel floating roof. The initial report stated that the workers were jacking the support legs in order to replace tank floor plate. One worker died and four were injured when the 120foot diameter steel IFR collapsed. This is not the first time an accident of this nature has occurred. Safety advantages Conventional legs are either fixed or two-position types. Fixed legs are generally set at about 4 feet above the tank bottom. Two-position legs usually have a low setting at the lowest level above the highest obstruction at the bottom of the tank, usually the shell manway, and a high setting at the maintenance level. With a manway plug the low setting will be about 3 feet (1 m). The high or maintenance position is usually about 6.5 feet (2 m) to give head clearance and provide a reasonable assembly height in the case of an AIFR. A cable suspension system allows multiple height settings not possible on a steel IFR. Therefore, in addition to the low and high posi-

tion, our customers often specify a third position. We call the third position a high/high position, and it is usually set at around 15 feet (4.5 m). This third position provides clearance for future maintenance to the bottom of the tank such as bottom repair or replacement. The 15-foot position allows the contractor to bring a bobcat and other equipment into the tank to replace floor plate. Working on a tank floor without having to deal with support legs greatly improves safety and efficiency and significantly reduces the repair time and costs. In any case, the absence of legs is indeed an additional benefit when tank cleaning occurs. It is much easier and safer to clean a tank without having to negotiate around legs that can be moved and or damaged in the process. While on the subject of leg damage, conventional legs are frequently subject to corrosion damage, especially in crude oil service. In tanks with steel IFRs, it is not uncommon to find tank floor damage caused by heavy steel roof landings. Additionally, the absence of legs greatly improves the ease and speed of personnel evacuation should it become necessary. Emissions reduction potential For the purposes of the rest of this article all references and calculations will be made on a tank that is 120 ft (36.6 m) in diameter, 48 ft (14.6 m) high, with a fixed roof with eight roof support columns.

This is a reprint from the May 2006 issue of Hazardous Cargo Bulletin, presented with the compliments of Allentech

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It is equipped with an aluminum IFR and is located in Houston, Texas, US. It is assumed the product service is motor gasoline with a Reid Vapor Pressure of 10 psi and the tank experiences 36 turnovers per year. All calculations are based on the US Environmental Protection Agency (EPA) Tanks 4 program, the standard method for calculating emissions losses for permitting and enforcement purposes in the US. More information can be found on the US EPA website at http://www.epa.gov/ttn/chief/ap42/index.html. In simple terms, using the Tanks 4 program calculations, eliminating conventional two-position legs and replacing them with a cable suspension system on a new AIFR or by retrofitting an existing AIFR with a cable system that seals off the leg sleeves reduces vapour emissions by approximately 30 per cent. The subject 120-foot tank with an aluminium pontoon IFR with 75 legs and a primary shoe seal emits 17,232 lbs (7.8 t) per year. Replace the conventional legs with a cable system and it emits a total of 11,854 lbs (5.4 t) per year. Although it is not possible to remove the legs and cable suspend a steel IFR because of its weight, it is possible to retrofit an existing AIFR with a cable suspension system. Allentechs retrofit design completely seals off all leg sleeves, eliminating all leg sleeve emissions. It is important to mention this because we have seen

cable systems in the field that do not. The latest technology in bolted seams for AIFRs has the potential to further reduce emissions. The Tanks 4 program has a default factor to calculate the emissions losses though the total number of linear feet of bolted seams on an AIFR. This factor is 0.14 lbmol/(ft yr). Using this factor the resultant loss is 5,488 lbs per year in our subject tank. EPA allows for alternative control devices if the emission factor is less than the standard but this alternative factor must be the result of independent testing using strict EPA protocol and criteria. The bolted seam illustrated, manufactured in the US by Allentech and used in its Full Contact Honeycomb AIFR has a factor of 0.0085 lbmol/(ft yr). Utilizing this factor in our subject tank results in an emissions loss of only 333 lbs per year. Cost savings too Generally speaking, a new aluminium skin and pontoon type AIFR will cost one half or less than the price of a steel pontoon IFR. The more expensive aluminium honeycomb full contact type IFR will be competitive with and probably in most cases cost less than a steel pontoon IFR. With the addition of a cable suspension system to either design operational costs are also reduced due to the time savings during maintenance discussed at the start of

this article. With mobilisation the leg change job will probably cost about $9,000. The approximate cost of the cable suspension system for our subject tank is $15,000. This gives the purchaser a payout for the system after less than two leg changes. In both cases the aluminium IFR can be installed in as existing tank without a costly door sheet and subsequent hydro test. Additionally, the installation time for an AIFR is generally about one-third that of a steel IFR, saving money on installation and tank downtime. When AIFRs were introduced about 40 years ago they were a very low-cost alternative internal floating roof with problems. Over the years conscientious manufacturers have solved the problems and in so doing produced a product that is more than a low-cost alternative. High quality AIFRs today have an operational life of 30 years or more. They are reliable but still economical. And, as detailed in this article, quality cable-suspended aluminium internal floating roofs greatly improve safety and dramatically reduce emissions. *Bill Grimes is a sales engineer for Allentech (Bethlehem, PA), which designs, manufactures and installs aluminium internal floating roofs, perimeter seal systems, and related products for aboveground petrochemical storage tanks. telephone: (+1 520) 575 1443; e-mail: billg@allentech.com.

This is a reprint from the May 2006 issue of Hazardous Cargo Bulletin, presented with the compliments of Allentech