2018, Rural Bulk Fuel Facility Upgrade
Integrity was contracted by the joint owners of an extremely remote rural facility to assess the condition of the infrastructure and to assess regulatory compliance with applicable plans and permits in place. Integrity’s final analysis report guided a targeted $475,000 engineering improvement project that repaired four of the six horizontal fuel storage tanks to STI SP001 standards, replacement of all water draw nozzles, piping and pumps, replacement of the dispensing mechanism, and added considerations for safety, building, and fire codes. Integrity partnered with both the design engineering team and the mechanical repair team and gave significant input into the design and repair options considered. All permits and plans were updated to streamline record keeping and reporting requirements and all on-site personnel received quality training in record keeping, annual maintenance requirements, and general housekeeping and inspection checklists.
Integrity’s strong communication skills and network with local, state, and federal regulators ensured that compliance was achieved at this facility with no loss of integrity, no notices of violation, and in partnership with the local community. This project resulted in the extension of the facility life to over 20 years, improved safety for facility personnel and community members utilizing the card lock station, significantly reduced risk exposure for the owners, and increased fuel storage capacity for the community.
Of note in this project was the cost savings for rehabilitating and repairing tanks rather than replacing them, and the use of a phased repair schedule to ensure ullage was available around the limited barge delivery schedule available in this remote location. It is estimated that this approach saved the clients $725,000 by avoiding a complete facility replacement.
2017 - Present, On-going Contracted Inspection Program
Integrity manages a cost effective and efficient annual tank inspection program for a company with multiple facility locations across South East and South Central Alaska. This program manages the inspections for hundreds of field constructed and shop-built tanks.
Integrity provides historic inspection auditing, develops an annual inspection plan, and performs all API 653 internal and external inspections, STI SP001 inspections, API 570 piping inspections, and annual cathodic protection system surveys. Because our lead inspector is on-site for all inspections, Integrity also performs NDE services on areas of concern, identifies potential problems early, and partners with local contractors to provide tank, pipeline and containment repairs.
This program has resulted in the elimination of late or missed inspections, saved the client money by planning ahead for cost savings, and strengthened the client’s relationships with the State of Alaska and federal regulatory agencies as well written and easy to read reports are delivered on-time year after year.
Project: Plans & Permits
Moose Creek Tank Farm Facility
A large 500,000-barrel bulk fuel storage facility was constructed near North Pole, Alaska between 2020 and 2021. Integrity Environmental LLC was chosen to perform all the environmental operational permitting at the local, state and federal level.
The site was particularly challenging due to the developing state and federal regulations surrounding perfluorooctanoic acid and perfluorooctane sulfonate (referred to as PFOA and PFOS, respectively). These are fluorinated organic compounds that are part of a larger group of compounds known collectively as perfluoroalkyl substances (PFAS). The groundwater underlying the site had been historically contaminated with PFAS by the nearby Air Force base.
By the time the operational planning process started, the State of Alaska had drastically changed how they allow PFAS contaminated water to be used. The State also declared a Critical Water Management area in the exact location of the tank farm project. This presented critical engineering challenges.
Integrity Consultants worked with State regulators within the Alaska Division of Mining, Land and Water and the Alaska Department of Environmental Conservation to determine how the developing PFAS guidelines would impact the engineering of the fire-fighting system and the tank construction. Impacts to storm water management and oil spill response tactics used at the site were also analyzed and adapted to minimize interaction with the contaminated water.
In a typical tank farm construction project, large amounts of water are used in both the tank integrity testing and in the firefighting systems. However, at the North Pole site, because the ground water was contaminated with PFAS, there was no other viable water source. Alternative testing methods allowed under the engineering standard API 650 had to be utilized, and an alternative firefighting system had to be developed.
Integrity’s permitting experts played a vital role in finding solutions and working with the State of Alaska for approval of alternative API 650 testing methods, design changes, and an effective Oil Discharge Prevention and Contingency Plan (ODPCP). Our consultants’ vast knowledge of State regulations and the API 650 standard strongly supported the project.
Despite its unique challenges, this tank farm was finished and ready for operations at the beginning of 2022. Integrity was lauded by the Project Team for their professionalism, ability to meet permit issuance timelines despite the many unanticipated changes, and attention to detail on all State submittals and record keeping.