API 2026 Question ?

[Gianoli]

API standard 2026 - "Safe Access/Egress Involving Floating Roofs of Storage Tanks in Petroleum Service" outlines, as the title suggests, a number of considerations prior to entering onto various types of tank roofs.

My question concerns tanks with internal floating roofs. We have a number of tanks in service with internal floating roofs constructed of foam panels with a thin skin tied together with an aluminum grid. No pontoons. We have in the past entered onto these roofs while the tanks were in service. I am curious what the current practice is in other companies. API 2026 does not forbid the practice but seems to outline a number of significant concerns.

Is accessing this type of roof while in service a common practice? I have spoken a number of tank operators/owners who no longer consider this practice safe. Any feedback is appreciated.

 

[Bonswa]

I dont remember reading too much about this from my API-TES exam, but most of the refineries i've worked for have the same practice and procedure when it comes to IFR's.

I'm not sure what your reason is for entering onto an IFR while in service. There's only two times that i've dealt with it. Other then what i'm about to mention, it's prohibited at the sites that i've worked for.

The first scenario was to inspect the roof legs before landing the roof to take it out of service. This is a standard procedure at a few sites.

The only other time was to verify the extent of seal damage that was identified during a visual seal inspection from the inspection hatch.

In both scenarios, it is MANDATORY to be under fresh air / SCBA. It is also MANDATORY to have a tripod and wench setup above the inspection hatch for retreival. One key element is the amount of people. If ONE person can perform the job, then only ONE person enters the roof. Keep the smallest amount of workers on the roof as possible to perform the task. In both of the scenarios above, only one worker was required. Other than that, the rest of the PPE is standard based on the product stored in the tank.

As far as the roof flat/pan type roof... the same procedure applies, although it is prohibited to have more than one worker on the roof. If there's a job that takes more than one worker, then it does not get done, and the tank must come out of service.

One of my sites just landed the roof of a 120' IFR Benzene tank. We set up the entry exactly as stated above. In addition to that, the entrant was wearing all of the PPE that is required for Benzene atmosphere. He had SCBA, full Acid Suit, Rubber Boots and rubber Gloves. He was even required to put that special lotion on any other exposed body parts.

I hope this helps.

 

[ARC12]

At the facility I work in the practice is strictly forbidden; no exceptions. You don’t mention what type tanks you have or the product you are dealing with in the tanks. You reference API 2026 so I assume you are in the petrochemical business and dealing with tanks containing hydrocarbon liquids.
In general, I don’t believe there are many tank operators who consider the practice safe. You are correct in mentioning that API 2026 does not forbid the practice however, being able to protect the entrants from a number of potential hazards listed in API 2026 is not often possible while in the confines of a confined space. Much depends on the type of tanks you operate, the number of egress avenues available, and the type of internal roof you have.
Any type of hot work is absolutely forbidden. Some types of cold work are permissible however you must be able to protect the entrants from all potential hazards they may encounter. These hazards can include atmospheric, chemical and physical. The sudden unexpected appearance of hydrocarbon liquid onto the roof can quickly turn the environment extremely dangerous. This did happen in a facility I worked in the past and I recall the comment was made “we were lucky to get him out”.
You really need to ask yourself is the risk acceptable and are you truly prepared to deal with any potential hazard that may materialize. In most cases the answer is no.

 

[IFRs]

You need to find a contractor who is experienced, qualified and intimately familiar with the design and construction of the IFR. It helps if the company is in the floating roof business. At my previous company I was one of the only two people allowed to make such entries. Many owners just don't allow it because of the risks.

 

[Bonswa]

Alot of sites DO forbid entry onto an internal floating roof while in service, however those sites probably have not dealt with taking a tank out of service, opening the shell manway, and finding that your IFR is laying flat on the ground; because 90% of the roof legs have failed. At one time it was forbidden at this site, until they saw the roof damage that was done; which could have been prevented had they taken the time to enter the roof and inspect the legs before landing.

As a matter of fact. The requirement of the roof leg inspections on an IFR is the EXACT reason that i was required to take the API-TES exam. In then end, although useful, the exam really didnt

Yeah, i agree there's a high risk. So, you have a risk meeting or risk analysis meeting or whatever your site does. Each contractor involved, safety, and the owner/user of the tank get involved and discuss what could potentially happen and how to prevent it.

 

[ARC12]

Make no mistake; this is a high-risk activity. Carefully evaluate your egress options should you need them. Many older cone roof tanks only had one roof entry point. If your entrant is working 100’ feet away from this point and needs to be retrieved, you’re in serious trouble. Dragging the entrant 100’ across an internal roof with a SCBA on, over all kinds of obstacles, and then hoisting the entrant up to the entry point is totally unacceptable. This is where the hazard assessment process ended for the tanks in our facilities.

 

[IFRs]

This was in a large part why I started to design and recommend cable suspended floating roofs quite some years ago.