650-706 rev 0 ballot2302
DESCRIPTION
650-706 revTRANSCRIPT
Ballot Comments and Resolution
Page 1 of 1
Ballot: 2302 Name: 650-706 Rev 0 - Internal Floating Roof Leg Vent Setting Report Date: 4/25/2011 Closing Date: 4/20/2011
Proposal: To review and approve 650-706 Rev 0 - Internal Floating Roof Leg Vent Setting.
Name Vote Comment Proposed Change Comment Resolution Attachment Company Email Phone Country
1 Grocki, John Not qualified to comment 860 985-8430
2 Broad, Tad All Sections General 803 520-2727 USA
3 Erdmann, Kenneth All Sections General 918 624-6265 USA
4 Roberts, Bruce Guest All Sections Technical Change "owner" to "Purchaser". API Consultant 281 252-8626
5 Kennedy, Karen All Sections General Several comments and clarifications received. Will be reballoted Rev 1 Fall 2011. ConocoPhillips 281 293-3594
6 Richardson, Michael Section/Clause General 651 438-7523 USA
7 Adolphsen, Steven Guest Section/Clause H Technical CBI Services 425 258-2350 USA
8 Kissell, Randy Section/Clause H.5.2.1.2 General H.5.2.1.2 should not require leg actuated vents. Strike the first sentence of section H.5.2.1.2. TGB Partnership 919 644-8250
9 Rosenkrantz, David Section/Clause H.5.2.1.4 Technical 610 349-4429
10 Kobialka, Ron Section/Clause H.5.2.1.4 Technical 832 472-2304
11 Hagen, Ty Section/Clause H.5.2.1.4 Technical 651 686-5686
12 Naidu, Pusp Guest Section/Clause H.5.2.1.4 Technical Canada
13 Morovich, George Section/Clause H.5.2.1.4 Technical 979 247-4812
14 Lieb, John Section/Clause H.5.2.1.4 Technical 630 226-0745 USA
15 Kissell, Randy Section/Clause H.5.2.1.4 General Change "activated vents" to "actuated vents". TGB Partnership 919 644-8250
16 Kissell, Randy Section/Clause H.5.2.1.4 General The height needs to meet certain criteria. TGB Partnership 919 644-8250
17 Cooper, Hally Section/Clause H.5.2.1.4 Editorial 907 787-8029
18 Baker, Mark Section/Clause H.5.2.1.4 General 614 410-5348 USA
19 Hiner, Larry Guest Section/Clause H.5.2.1.4 Technical CB&I 815 439-6125
20 Nadel, David Guest Section/Clause H.5.2.1.4 Technical 713 372-7155
Sort Key
SectionType
ClauseSubclause
Number
Type ofComment
Abstain
Advantage Resources Consulting, LLC
United States
Affirmative
Add Section Number here.
Would like to see 6" left as the recommended unless something else is agreed upon. Some guidance should be provided.
automatically at a point agreed upon by the owner and manufacturer, recommended opening is 6" above lowest operating position.
Fisher Tank Company
Affirmative
Add Section Number here.
Should be provide cautionary statement regarding differential bottom settlement? If the vent only contacts the bottom 2 inches priot to legs and the tank is on poor soil where differential variations in bottom settlement can exceed 2 inches then the vent leg could potentially not open in the as settled condition. API-653 checklist already has inspector document the height that this opens. Previously this would always be compared to 6 inches where now every tank may be different. Should 653 item be taken out to mention this needed check against a tanks specific stand off?
Include cautionary statement that the vent leg should be sized to contact the floor prior to the roof legs and that this offset should consider future floor differential settlement that is expected to occur.
Matrix Service Company
Add Section Number here.
650 is for new construction, so the Purchaser and Manufacturer have to make the agreement.
United States
Affirmative
Add Section Number here.
United States
Negative
Add Section Number here.
Having no minimum concerns me. I could imagine an agreement of one inch. I have assumed that the six inches helped with irregularities in the floor or roof.
... at a point agreed upon by the owner and manufacturer but not less than X.
Flint Hills Resources
A default height must be left in the wording. Not all owners want to have to make this decision.
ADD the words "... as agreed upon by purchaser and manufacturer. If unspecified, then opening shall be set at 150 mm (6 in.)."
Negative
United States
Negative
I don't see why only float-activated vents should be required to remain closed while the roof is floating. In addition, the suggested wording combines 40CFR60 Kb and 43CFR63 WW.
Pressure and vacuum vents shall be equipped with a gasketed closure and are to be closed at all times when the roof is floating except when the roof is being floated off or is being landed on its supports or when required to be open to relieve excess pressure or vacuum, in accordance with the manufacturer’sdesign.
Access Engineering, LLC
United States
Negative
Recommend a default position of 6 inch which can be changed with mutual agreement. H.5.2.1.4 Leg or cable activated vents shall be
designed to open automatically when the roof lowers to 150 mm (6 in.) above its lowest operating position and to close automatically when the roof raises more than 150 mm (6 in.) above its lowest position unless a different setting is agreed upon by the owner and manufacturer.
ExxonMobil Research & Engineering
United States
Affirmative
1. The height of the opening can affect the design (sizing) of the vent by limiting the flow area. 2. I think the existing wording should be the default and new wording added to allow the opening/closing height to change by agreement between the owner and manufacturer.
H.5.2.1.4 Leg or cable activated vents shall be designed to open automatically when the roof lowers to 150 mm (6 in.) above its lowest operating position and to close automatically when the roof raises more than 150 mm (6 in.) above its lowest position ...unless these positions are changed to other heights agreed upon by the owner and manufacturer.. Float-activated vents shall be designed to remain closed while the roof is floating. Pressure-vacuum activated vents shall be designed to open and achieve required flow rates within the design capacities of the floating roof and floating roof support system as described in H.5.2.1.1.
Hagen Engineering International, Inc.
United States
The proposed change is acceptable however I offer the following suggested change.
Leg or cable activated vents shall be designed to open automatically at a point agreed upon the Purchaser and Manufacturer. The point at which the vents open shall be set to maximize product drawoff from the tank however due consideration shall be given to prevent damage to the floating roof due to vacuum conditions.
Shell Canada Energy, Ltd.
403 38478 14
Negative
The attached proposes to eliminate the requirement for the PV vent to open when the roof is 6" from the bottom. There is a reason for the 6" dimension - Per H.4.1.5 the roof is required to set 4" into the liquid at SG=0.7 (at higher SG the 4" dimension is reduced and lower SG increased), so this range is the point where negative pressure can develop when emptying the tank and where the vents must be open. Karen was called and spoke to Larry Foster who agrees the dimension is not arbitrary, but does want to allow the option to minimize. The other consideration is all manufacturers have a Standard P/V vent and this change may eliminate the use of their Standard.
Our suggestion is to leave the 6" Standard as default "unless specified otherwise", and reference H.4.1.5.
Tank and Environmental Technologies, Inc. (TETI)
United States
Negative
I think that eliminating the 6" limits and replacing them with the proposed new wording makes this section more arbitrary than it was with the limitations. The 6" requirement may have been set to allow for imperfections in the bottom construction or settlement in the case of the leg-actuated floats. The proposed wording would require the purchaser/manufacturer to perform an engineering evaluation, considering API 2000, possible construction imperfections and other factors that are not adequately defined with the proposed wording. There could be serious consequences if the vents do not open properly or fully. I think we are making the standard "less safe" in this case. I would not be opposed to modifying the proposed new wording (but keeping the current limits) as suggested herein.
Consider changing proposed wording similar to following: "Leg or cable activated vents shall be designed to open automatically at a point agreed upon by the purchaser and manufacturer, based on a documented engineering analysis that considers the provisions of API Standard 2000, potential construction imperfections, and future tank settlement. In the absence of such an analysis,the vents shall be designed to open automatically when the roof lowers to 150 mm (6 in.) above its lowest operating position and to close automatically when the roof raises more than 150 mm (6 in.) above its lowest position.
Tank Industry Consultants, Inc.
Negative
Environmental regulations call these "actuated vents", not "activated vents".
United States
Negative
Change "automatically at a point agreed upon by the owner and manufacturer" to "automatically at a height that is sufficient to prevent vacuum or pressure from damaging the floating roof when the roof lands on its supports or is floated off its supports"
United States
Affirmative
the proposed change does not address closure of these vents as in the original text.
H.5.2.1.4 Leg or cable activated vents shall be designed to open and/or close automatically at a point agreed upon by the owner and manufacturer
Alyeska Pipeline Service Company
United States
Affirmative
Suggest setting another alternate minimum to account for variables such as roof flexing, adjacent roof leg issues, settlement, etc. or at least mention that these should be considered. Also, Suggest requiring documentation of set point if set less than 6”.
Specify an alternate minimum and require documentation of the set point if set less than 6" to avoid confusion.
Baker Consulting Group, Inc.
Negative - The current elevation of the bottom or cable activated vents allow for uneven settlement of the bottom, tliting of the floating roof, or deflections of the fixed roof. Verification by physical inspection of vent opening is either difficult or not allowed by operating procedures.
H.5.2.1.4 Leg or cable activated vents shall be designed to open automatically at a point agreed upon by the owner and manufacturer. >> This point shall consider uneven settlement of the bottom and tilting of the floating roof and defection of fixed roof anchor points.<<
United States
Most people who buy tanks are not knowledgable and certainly do not know all the caveats we have created> I propose "hybrid" preceding the beginning of the sentence.
"Unless agreed upon by the owner and manufacturer, the leg or cable activated vents shall be designed to open automatically when the roof lowers to 150 mm (6 in.) above its lowest operating position and to close automatically when the roof raises more than 150 mm (6 in.) above its lowest position.
Chevron Energy Technology Company
United States