CommentsOn - American Petroleum Institute



|Douglas Miller |9.10.2.2 |Editorial |The last two sentences contain a lot of redundant wording. Both |9.10.2.2 New bearing plates for fixed roof| |

|Chicago Bridge & Iron | | |address conditions under which spacers can be used in lieu of pads.|support columns shall be installed. For | |

|Company(CB&I) | | |The last sentence seems to cover it all and the second from last |steel floating roof legs, steel pads or | |

|(Affirmative) | | |sentence can be deleted without loss of any meaning. |other means shall be used to distribute | |

| | | | |the loads on the bottom of the tank and | |

| | | | |provide a wear surface. If pads are used,| |

| | | | |they shall be continuously welded to the | |

| | | | |tank bottom. For aluminum floating roofs,| |

| | | | |austenitic stainless steel or acceptable | |

| | | | |non-metallic (e.g. Teflon) spacers may | |

| | | | |installed to isolate legs from the carbon | |

| | | | |steel bottom instead of welded pads if the| |

| | | | |spacers will not damage bottom coatings, | |

| | | | |there is no evidence of corrosion damage | |

| | | | |from such spacers on the previous bottom, | |

| | | | |and if the owner/operator approves. | |

|Craig Meier |API-653, |Editorial |I agree with the concept of the proposed change, therefore the |9.10.2.2 Fixed roof support column | |

|ConocoPhillips |9.10.2.2 | |affirmative vote. API-650 does a good job of outlining |bearing plates shall be installed per | |

|(Affirmative) | | |requirements however, and I see no reason not to simply refer to |API-650 5.10.4.7. Floating roof bearing | |

| | | |API-650 instead of duplicating/adding more text to API-653. |plates shall be installed per API-650 | |

| | | | |H.4.6.6 – H.4.6.9, with the word | |

| | | | |Owner/User replacing the word Purchaser. | |

|Robert Steinhart | |Technical |Since cable suspended aluminum floating roof are beginning to be | | |

|ConocoPhillips Company | | |more accepted across the general industry, a short comment in the | | |

|(Affirmative) | | |proposed API-653 change should address the steel pads are not | | |

| | | |required for aluminum IFR that are cable suspended. | | |

|Jerry Boldra | |Technical |It appears to me that this one LOOOONG paragraph would be easier to|1st Paragraph - first sentence: New | |

|D.J. "Jerry" Boldra | | |read and follow . . . and to "come back to in the future" . . . if |bearing plates for . . . | |

|Consulting Engineer | | |it were divided into three paragraphs. I think it would read |2nd Paragraph - 2nd and 3rd sentence: For| |

|(Affirmative) | | |better too. |steel floating roofs . . . | |

| | | | |3rd Paragraph - remainder of the proposed | |

| | | | |paragraph: For aluminum floating roofs . | |

| | | | |. . | |

|Tearle Taylor |9.10.2.2 |Technical |Comments as follows: |Leave the paragraph as-is and strengthen | |

|Flint Hills Resources | | |1."For steel floating roof legs, steel pads or other means shall be|API 650 to follow suit. | |

|(Negative) | | |used to distribute the loads on the bottom of the tank and provide | | |

| | | |a wear surface." This is not defined well, it allows too many | | |

| | | |variables that may lead to a sense of false security. | | |

| | | |2."For aluminum floating roofs, the pads may be omitted if the | | |

| | | |owner/operator approves and new austenitic stainless steel or | | |

| | | |acceptable non-metallic (e.g. Teflon) spacers are installed to | | |

| | | |isolate legs from the carbon steel bottom." Pads do not always stay| | |

| | | |intact and pinned austenitic SS pads at the bottom do not always | | |

| | | |land flat. | | |

| | | |3."For aluminum floating roofs, austenitic stainless steel or | | |

| | | |acceptable non-metallic (e.g. Teflon) spacers may installed to | | |

| | | |isolate legs from the carbon steel bottom instead of welded pads if| | |

| | | |the spacers will not damage bottom coatings, there is no evidence | | |

| | | |of corrosion damage from such spacers on the previous bottom, and | | |

| | | |if the owner/operator approves." If there is no Teflon pads or | | |

| | | |spacers how do assess the damage? | | |

| | | |4. Paragraph 9.10.2.2 was implemented due to the damage floating | | |

| | | |roof legs inflicted on tank bottoms. Many of these caused failures.| | |

| | | |Loosening the effectiveness of this paragraph negates the | | |

| | | |environmental effectiveness that was intended. | | |

|Brandon Austin |Proposed Change |Technical |The final sentence is somewhat confusing, particularly the manner |I would suggest something such as the | |

|HMT Inc. | | |in which it attempts to tie-in the previous sentence. |following: | |

|(Affirmative) | | | | | |

| | | | |For aluminum floating roofs, the pads may | |

| | | | |be omitted with owner/operator approval. | |

| | | | |Alternately, new austenitic stainless | |

| | | | |steel or other acceptable non-metallic | |

| | | | |(e.g. Teflon) spacers may be installed to | |

| | | | |isolate legs from the carbon steel bottom | |

| | | | |provided that (a) these spacers will not | |

| | | | |inflict damage upon bottom coatings, (b) | |

| | | | |there is no evidence of corrosion damage | |

| | | | |from such spacers on the previous bottom | |

| | | | |(or other bottoms within the same | |

| | | | |facility), and (c) if the owner/operator | |

| | | | |approves. | |

|Doug Bayles |Section 9.10.2.2|Editorial |Second sentence says the steel pads "shall" be used, but the next |9.10.2.2 New bearing plates for fixed roof| |

|Inserv Integrated | | |sentence stated "if" pads are used. Third sentence should be |support columns shall be installed. For | |

|Service Company LLC | | |edited without the if. |steel floating roof legs, steel pads or | |

|(Affirmative) | | | |other means shall be used to distribute | |

| | | |Last two sentences seem redundant. See suggest wording below. |the loads on the bottom of the tank and | |

| | | | |provide a wear surface. Steel pads shall | |

| | | | |be continuously welded to the tank bottom.| |

| | | | |For aluminum floating roofs, austenitic | |

| | | | |stainless steel or acceptable non-metallic| |

| | | | |(e.g. Teflon) spacers may installed (in | |

| | | | |lieu of steel stiker pads) to isolate legs| |

| | | | |from the carbon steel bottom, if the | |

| | | | |spacers will not damage bottom coatings, | |

| | | | |there is no evidence of corrosion damage | |

| | | | |from such spacers on the previous bottom, | |

| | | | |and if the owner/operator approves. | |

|Chris Bashor |9.10.2.2 |Technical |The new wording of the 5th sentence addresses the concerns that I |Delete 4th sentence. | |

|Minnesota Pollution | | |raised in the previous ballot. I might point out that the 4th | | |

|Control Agency | | |sentence now is overlapped by the 5th sentence; I believe if the | | |

|(Affirmative) | | |4th is deleted, nothing is lost and the paragraph is more readable.| | |

|James McBride |9.10.2.2 |Editorial |There seems to be some repetitiveness when discussing aluminum |If the owner/operator agrees, for aluminum| |

|Petrex, Inc. | | |floating roofs. |floating roofs the welded pads may be | |

|(Affirmative) | | | |omitted and new austenitic stainless steel| |

| | | | |or acceptable non-metallic (e.g. Teflon) | |

| | | | |spacers may be installed to isolate the | |

| | | | |legs from the carbon steel bottom if it | |

| | | | |can be shown that the spacers will not | |

| | | | |damage bottom coatings and if there is no | |

| | | | |evidence of corrosion damage caused by | |

| | | | |such spacers on the previous bottom. | |

|George Morovich | |Technical |Have seen legs wear completely through bearing and bottom plates. |Suggest to drop this item | |

|TEMCOR | | |Also legs have been seen corroded away due to galvanic corrosion | | |

|(Negative) | | |(dissimilar metals in presence of the water bottom as the | | |

| | | |electrolyte). | | |

|Randy Kissell |9.10.2.2 |Technical |The last two sentences are somewhat confusing and repetitive |Change to | |

|TGB Partnership | | |wording is used. |"For aluminum floating roofs, the pads may| |

|(Affirmative) | | | |be omitted if: | |

| | | | |a) the owner/operator approves and | |

| | | | |b) new austenitic stainless steel or | |

| | | | |acceptable non-metallic (e.g. Teflon) | |

| | | | |spacers are installed to isolate legs from| |

| | | | |carbon steel bottoms if the spacers will | |

| | | | |not damage bottom coatings, and there is | |

| | | | |no evidence of corrosion damage from such | |

| | | | |spacers on the previous bottom. | |

|John Mooney |last sentence |Editorial |This is a very long sentence and it could be shortened by | | |

|(Affirmative) | | |separating the last 3 phrases into bullet or item numbers (i.e | | |

| | | |1,2,3) | | |

|Thomas Lorentz |9.10.2.2 |Technical |I do not have a problem with the intent of the revision. However, |For aluminum floating roofs, the pads may | |

|AEC Engineering, Inc. | | |the proposed wording for the conditions requiring owner approval |be omitted if the owner/operator approves | |

|(Negative) | | |for aluminum roofs would theoretically allow the owner approve |and new austenitic stainless steel or | |

| | | |omitting the steel wear pads, and then to say no to installing the |acceptable non-metallic (e.g. Teflon) | |

| | | |spacers for isolation. I'm not sure we need the owner approval |spacers are installed to isolate legs from| |

| | | |comment twice. |the carbon steel bottom. For aluminum | |

| | | | |floating roofs, austenitic stainless steel| |

| | | | |or acceptable non-metallic (e.g. Teflon) | |

| | | | |spacers should only be installed to | |

| | | | |isolate legs from the carbon steel bottom | |

| | | | |if the spacers will not damage bottom | |

| | | | |coatings, and there is no evidence of | |

| | | | |corrosion damage from such spacers on the | |

| | | | |previous bottom. | |

|Steven Adolphsen |9.10.2.2 |Editorial |affirm without comment | | |

|CBI Services | | | | | |

|(NonVoter) | | | | | |

|Larry Hiner |9.10.2.2 |Technical |This section applies to both external and lnternal floating roofs. |9.10.2.2 New wear plates for fixed roof | |

|Chicago Bridge & Iron | | |Not all fixed roof columns have bearing plates. API 650 now |support columns requiring wear plates per | |

|Company(CB&I) | | |requires wear plates unless a sealed bearing plate is used. It may |API 650 shall be installed. For steel | |

|(NonVoter) | | |not be necessary to replace bearing plates which can be large and |floating roof legs on external floating | |

| | | |over an inch thick For internal floating roofs only , alternate |roofs, new pad plates under the legs per | |

| | | |means for distributing loads or providing a wearing surface may be |API 650 requirements shall be installed. | |

| | | |provided. |For internal floating roof supports other | |

| | | | |means may be used to distribute the loads | |

| | | | |on the bottom of the tank and provide a | |

| | | | |wear surface. For aluminum floating roofs | |

| | | | |- - | |

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