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EIT Standard for Existing UPSS

Shell Retail Network Engineering

Equipment Integrity Testing Standards for Existing Underground


Petroleum Storage Systems

Standardisation level
Principles
Functional specification
Technical specification
Product sheet
Procedure

Ref. Number: EIT. MB01


Rev. Number: [0.3]
Issue Date: 18/02/09
EIT for existing UPSS

Document Semantics

Standardisation Document Metadata

Name: Equipment Integrity Testing Standards for Existing UPSS

Description: Engineering Standard

Reference number: EIT.MB01

Issue Date: 18/02/09

Review date: Annually

Void date: Revision Required 25/11/2009

Author: Michael Briese

Content owner: Michael Briese

Area of validity: Shell, PMC, FMC

Governing Superior
Documents:

Revision Number: 0.3

Key Words: EIT, Equipment, Testing, UPSS

Standardisation
Control:
Standard

Standardisation Area:

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Amendment History

Revision Nr. Revision Date Author(s) Short change description

0.1 22/07/2008 Michael Briese First draft

nd
0.2 25/11/08 Michael Briese 2 draft

1.1 18/02/09 Michael Briese First issue

Disclaimer
" The requirements and guidelines set out in this document shall not apply or be implemented to the extent that they do not meet the requirements
of applicable laws and regulations. In all cases, all applicable legal and regulatory requirements must be met when conducting activities
associated with this document."

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Table of contents
Document Semantics .................................................................................................................................................... 2

Glossary of terms........................................................................................................................................................... 5

Introduction..................................................................................................................................................................... 6

Principles and Summary of Test Procedures............................................................................................................ 8

Line and Tank Testing Protocols............................................................................................................................... 12

Testing Equipment....................................................................................................................................................... 17

Contractor Requirements ........................................................................................................................................... 20

Personnel requirements ............................................................................................................................................. 21

Permit to Work requirements for EIT ........................................................................................................................ 24

Site Preparation for EIT............................................................................................................................................... 25

Appendixes ................................................................................................................................................................... 27

1.1 Approved EIT Contractors and Technologies.......................................................................................... 27

1.2 Choosing an alternative tank test .............................................................................................................. 27

1.3 Detail Service Request Form....................................................................................................................... 28

1.4 Existing procedures for investigating Loss, PLIP ................................................................................... 30

1.5 When to Initiate EIT....................................................................................................................................... 32

1.6 Failure Types ................................................................................................................................................. 34

1.7 Failure Types and Actions........................................................................................................................... 35

1.8 Reference Documents.................................................................................................................................. 36

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Glossary of terms
ALARP As low As Reasonably Practical
CoE Centre of Excellence
CMAS Contractor Management Accreditation System
DW Double Wall, term used for secondary containment pipe and UST
D&S Design and Standards
EIT Equipment Integrity Testing
FMC Facilities Management Company
GEMS Global Environmental Management Standards
Pressure Dispensing systems that split the pump from the dispenser, pump
Systems contained within the tank pressurising the dispensing line
NWGLDE National Work Group on Leak Detection Evaluations
PLLD Product Line Leak Detection – Used on Pressure Systems
PLIP Product Loss Investigation Procedure
PMC Project Management Company
PM Project Manager
PTW Permit To Work
SIRA Statistical Inventory Reconciliation Analysis
Siphon Systems which see UST’s connected through common pipe work, a
Systems pump or dispenser/s operating from two or more tanks at the same
time
Suction Dispensing systems that incorporate the pump and liquid meter
Systems within the one dispenser housing, lifting product from the tank
under vacuum
SW Single Wall. Term used for piping and UST that have primary
containment without secondary containment
SFL Safe Fill Level
UPSS Underground Petroleum Storage System

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Introduction
EIT (Equipment Integrity Testing) is a technology that’s used to check the physical integrity of UPSS (Underground Petroleum
Storage System). Many service providers exist throughout the world however, this standard identifies with one method that is
preferred based on a criterium for Vacuum testing and a certified detectable leak rate.

The purpose of this Standard is to provide a consistent approach to Shell Project Managers and representatives (FMC and PMC)
across the Shell Retail Networks for the testing of existing underground storage tanks and associated equipment that are at Shell
branded retail locations i.e. Shell has ownership of the UPSS.

This standard identifies


1. The tank testing method and leak rate criteria
2. The contractor requirements, accreditation and reporting process
3. PTW and site preparation requirements
4. A preferred list of tank testing companies and locations
5. A process for selecting suitable tank testing methods that meet this standard
6. The operational requirements for EIT

This standard identifies with one testing method that is preferred based on the following criteria

1. Tank testing is conducted with Vacuum assisted by Acoustic or Mass sensors


2. That the technology has a recognised and certified minimum leak rate criteria
3. That the technology and its protocols are certified - listed by a recognised industry or body
4. Its operators are formally accredited – by the protocol developer
5. That the technology is consistent with its results and reporting processes
6. That the technology is safe in its use and any failure associated with the test has an ALARP impact to Health Safety and
Environment.

Shell’s commitment to HSSE is such that no one undertaking EIT should compromise safety in any way. If there is any doubt as to
whether or not an activity is safe; STOP, assess and determine the appropriate course of action to perform the work safely in
an environmentally sound manner.

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This standard is not designed to address any general or specific questions that may apply to a particular job or set of facts.
Contractors that undertake EIT are required to perform all work activities in a safe and environmentally sound manner in compliance
with all laws and regulations, and consistent with this standard.

This document shall be periodically reviewed and modified as appropriate by the Retail Network – Design Standards Engineering
Centre of Excellence (COE).
Annual updates will be published on the Network Engineering Design and Engineering Construction Standards Website.

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Principles and Summary of Test Procedures


In order to minimise pollution of the environment by product leakages from UST’s, a test on leak tightness may be required. In
accordance with the current GEMS this is especially appropriate for tanks associated with routine testing i.e.

• UPSS > 10years of service (Not including continually monitored systems)


• All UPSS when conducting product loss investigations

EIT on Existing Systems Only


This standard is only to be used across existing UPSS, new systems on installation are tested before and after backfill and are
certified and commissioned as ‘Fit For Use’. The Global standard for UST Installation and the Global Pipe Work specification
outlines the requirements as per the manufactures recommendations and Shell requirements for new installed systems.

Pressurisation of Tanks
Pressurisation of tanks and overfilling methods for testing tanks is not preferred under this standard as excessive pressurisation or
overfilling in any form can accelerate loss and can become uncontrollable once a leak occurs i.e. any pressurisation or overfilling of
a tank can cause significant loss associated with tank shell failure impacting the safety of the operator, asset and environment
however; some regulators stipulate methods of testing by pressurisation, check with the D&S CoE before committing to the pressure
testing of UPSS.

Pressurisation of Pipe Work


Pressurisation of pipe work associated with the UPSS is allowed where Pipe work can be mechanically isolated from the tank or
when vacuum cannot be applied, this must be conducted by a qualified person within an accredited tank test company under this
standard when determining loss or integrity issues.
Only Nitrogen can be used for the pressurisation of Pipework.

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Exceptions
The Standard does not set out to reduce or lower any existing standard that may exist, this must be viewed as the minimum criteria
for all Shell owned and branded Retail outlets however, regulatory compliance in all countries must be observed as testing methods
may differ to this standard e.g. pressure testing tanks.
It is expected that Shell Engineers, Shell Representatives, and Tank Testing Contractors are knowledgeable of the local
conditions and contents of this document prior to performing any EIT (Equipment Integrity Test) activities.
The engineering CoE can assist when implementing this standard to a new market.

Tank Testing Companies


A list of approved tank testing companies is contained with appendix 1.1

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EIT Criteria

The standard for EIT is set against recognised certified tank-testing methods that have been set against a globally accepted method
for the accreditation of leak detection systems i.e. the NWGLDE.
The National Working Group for Leak Detection Evaluations sets guidelines, monitors the performance and recognises EIT
companies through approved third party certifications, most countries accept this as the globally approved method for evaluating EIT
methods.

There are two key areas that make up this standard

1. Minimum detectable leak rate and


2. Tank testing method

Minimum Detectable Leak Rate

The objective of a minimum leak rate criteria is to help set a standard for the detection of leaks, and if present, detectable through
EIT i.e. ‘the test shall result in a conclusive statement whether the UST contains a leak or not.
In this context the term “no leak” means that there is “no leak” above the detection threshold, which implies that under operating
conditions if there is a leak it is equal or lower than 0.37 litres/hour (0.1 US gallon/hour).
The test procedure shall unambiguously state the detection threshold under test conditions and the relation to operating conditions.

Tank Testing Method

The testing method is based on applying under-pressure (vacuum) to the tank and registering Acoustic or Mass signals induced by
air or water ingress into the tank i.e. Leak Tightness Testing shall be carried out by the vacuum test method where the sensing
mechanisms shall be based on a combination of:

• Acoustic emission in gas section (ullage) as potential result of a gas jet.


• Acoustic emission in the liquid phase as potential result of rising bubbles by air ingress
• Liquid level or Mass type sensors as potential result of groundwater ingress or product loss

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A (partial) vacuum is applied so that the pressure on the bottom of the tank is lower than the pressure outside the tank. An acoustic
sensor is used to listen for the tell tale sounds that indicate bubbles in the product filled portion of the tank, a Mass sensor is used to
measure the loss or gain of product within the wetted portion of the tank, these sensors indicate the presence of water ingress or
product loss and are detected through these sensors placed at the within of the tank.

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Line and Tank Testing Protocols


Tests are to be conducted in the following order
1. Line tests i.e. all product delivery lines and lines that can be isolated from the tank ullage
2. Tank testing i.e. wetted tank shell and associated ullage, can include ullage associated pipe work where they cannot be
isolated

The possibility of line failure associated with product loss or water ingress into tanks being detected before the tank shell is
subjected to testing can change the conditions for the tank test e.g. product drain back from lines or ingress of water can alter the
conditions of the test. Lines must be tested prior to tank shell.
Tanks are to be dipped before testing commences for product and water level. Water should be removed from the tank before
testing commences.

The tank is to be isolated from the sites other UPSS i.e. any manifolded or shared pipe work needs to be isolated from other tank
systems at the time of the test.

1. See Site Preparation for EIT; page 26


2. Ensure that shared Pipework and equipment e.g. vents, VR1 and VR2 are not compromised by the test, and that all other
tanks must remain operational. If systems cannot be separated, consult with the PM before proceeding.
3. Conduct tests

* Important Note
1. Using pressure is potentially dangerous; check all associated fittings and valves for max pressure operation, do not
exceed manufactures recommendations for pressure, if in doubt remove or isolate from line.
2. The use of pressurised air is not permitted, Nitrogen pressure only.
3. When testing against spaded lines to tank top insure tank is in free venting condition, pressurisation of lines associated with
tank ullage can bypass causing an over pressurisation of tank shell.
4. The test conditions shall comply with the mode of operation as applicable in the tank station. Special attention is required for
cascaded tanks and interconnecting pipes. In case shut-off valves are present, these may be used to separate the tanks to
allow individual testing however, only when these fittings are pressure rated and confirmed to be suitable for said pressures.
When these are not the case, installation of isolation spades should be considered or isolate tanks from pipe work.
5. The maximum allowable under pressure shall not exceed the limits as dictated by plastic collapse of the tank.

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The following table identifies the types of tanks and minimum requirements for testing.
Tanks Test Parameters and Conditions
Steel Single • Vacuum test Ullage only, vacuum must not exceed 126mm Hg (5 inches Hg)
• Tank to be tested with product, minimum level 10% of SFL to Safe Fill Level and free of water
Wall • Vacuum testing to be conducted with two probes where access is available, positioned at opposite ends of tank.
• If using Mass detection probes, tanks are required to be at 75% of SFL.
• Isolations within tank chambers are required, where not possible treat as a system test
• Isolate all other equipment

Steel - Double • Tanks with vacuum or brine interstitial monitored space, if tank monitor holding no need to test tank shell. When chasing water ingress or loss associated with
tank, test Pipework associated with ullage independently of a tank or as a system test within the ullage
Wall • Vacuum test Ullage only, vacuum must not exceed 126mm Hg (5 inches Hg)
• Tank to be tested with product, minimum level 10% of SFL to Safe Fill Level and free of water
• Vacuum testing to be conducted with two probes where access is available, positioned at opposite ends of tank
Steel with FRP • If using Mass detection probes tanks are required to be at 75% of SFL
Liner • Monitor interstitial gauge for pressure or liquid level while testing
• Isolations within tank chambers are required, where not possible treat as a system test.
• Isolate all other equipment
FRP Single • Vacuum test Note; vacuum must not exceed 126mm Hg (5 inches Hg)
• Tank to be tested with product, minimum level 10% of SFL to Safe Fill Level and free of water
Wall • If using Mass detection probes tanks are required to be at 75% of SFL.
• Vacuum testing to be conducted with two probes where access is available, positioned at opposite ends of tank. If using Mass probe access via dip tube.
• Isolations within tank chambers are required, where not possible treat as a system test.
• Isolate all other equipment

Tanks with Testing conditions for modified or lined tanks should be checked with the manufactures recommendations for testing e.g. vacuum testing steel tanks with internal FRP
liners can void the warranty of the liner.
after market Your DS CoE can assist when undertaking these tests
linings

FRP Double • Vacuum test Note; vacuum must not exceed 126mm Hg (5 inches Hg)
• *Never apply a vacuum or pressure to the Hydro-guard reservoir and or wet interstitial space as doing so may cause damage to the primary tank. *
Wall • Tanks have interstitial space, brine filled, if brine level holding no test required on tank shell.
• Best results, vacuum test inner tank while monitoring interstitial space level, see manufactures recommendations for testing FRP DW Tanks
• Tank to be tested with product, minimum level 10% of SFL to Safe Fill Level and free of water
• If using Mass detection probes tanks are required to be at 75% of SFL.
• Vacuum testing to be conducted with two probes where access is available, positioned at opposite ends of tank.

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Line Testing

Line testing can be conducted independently of the tank or can be conducted as a system test associated with all lines connected to
the tank top.
Independently testing lines through a series of isolations from the tank is required when equipment e.g. dispensers, VR 2 are
showing signs of air ingress or overall performance issues.
Hydrostatic line testing against spaded or isolated fittings is preferred however, in some cases the isolation cannot be conducted as
the fittings are directly buried i.e. without access, in these cases a system test (which includes tank and lines) are tested together.
When failure occurs under a system test, the lines will need to be mechanically isolated from the tank so they can be eliminated
from the test/failures.

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The following table identifies the UPSS associated lines and minimum testing requirements.

Hydrostatic System Comments Max Pressure


with Test
Isolation
Suction   Hydrostatic with Isolation preferred. For steel Pipework up to 250kpa
On direct buried lines a system test can be conducted. If system test fails then lines will need to be Fibreglass Pipework 250kpa
Lines exposed and isolated to confirm test. Polyethylene 250kpa

Pressure  Isolation of Pipework within tank chamber required, *Do not test against ball or gate valves; see 1.5 times operating pressure up to
note below. Isolate electrics and tag out. Ensure system is recommissioned before opening and not exceeding 350kpa
Lines Single dispensers. *See additional notes on Electronic and Mechanical Leak Detectors
Wall
Pipe Work  All Pipework with secondary containment must have the interstitial open to atmosphere when For steel Pipework up to 250kpa
tested; remove the monitor gauge or primary pressure valve before testing. Fibreglass Pipework 250kpa
with Polyethylene 250kpa
secondary
containment
VR1  * Isolate VR1 at the tank tops, pressurize VR1 circuit across all tanks and ensure tank is free For steel Pipework up to 35kpa
venting. Lower Pressures as tank top adaptors and termination fittings usually untested Fibreglass Pipework 35kpa
components* Polyethylene 35kpa

VR2  This does not include central vac systems or VR2 hanging hardware for dispensers. Isolate all For steel Pipework up to 35kpa
associated equipment and test VR2 loop pipe work separately. Fibreglass Pipework 35kpa
Polyethylene 35kpa

Vent  Vents tested as part of the system, this could show up as ullage failure associated with the tank. For steel Pipework up to 35kpa
Any ullage failure found then vents should be isolated retested to eliminate from tank shell failure Fibreglass Pipework 35kpa
Polyethylene 35kpa

Dip Tubes  Dips tested as part of the system, this could show up as ullage failure associated with the tank. Any For steel Pipework up to 35kpa
ullage failure found then dips should be stung out at tank top or removed from the tank, tank FRP Pipework up to 35kpa
Dewater retested to eliminate from tank shell failure.
Direct Fill
Indirect Fill   Preferred isolated from tank via the overfill protection device. If direct buried test with tank. Any For steel Pipework up to 35kpa
ullage failure found then fill should be isolated at tank top or removed from the tank, fill retested to Fibreglass Pipework 35kpa
eliminate from tank shell failure. Polyethylene 35kpa

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*Electronic and Mechanical line leak detectors

Typically placed on the submerged pump inside the tank. They constantly monitor the integrity of the pressure piping between the
pump and the nozzles of the vending point.
The system incorporates an electronic or mechanical operated valve. This valve remains in the “open” position because of the
remaining pressure in the pressure piping, after the pump has stopped.
When a leak occurs, fuel will drain from the pressure piping, thus lowering the pressure. The valve no longer retains its open
position but moves into the “test” position or complete shut down of the pressure pump.

Testing of product delivery lines associated with pressure systems fitted with leak detectors should be considered when

1. The system shuts down the dispensers


2. Repeated slow dispensing rates
3. The leak detector has failed
4. Containment chambers and or dispenser sumps show signs of contamination

A single product delivered through pressure systems often links to other dispensers across the forecourt; isolations will need to be
conducted once all dispensers feeding from the common line are identified, tank testing companies should not test against the leak
detectors or under pump emergency shut off valves.

Testing Line Leak Detectors

Line leak detectors are to be tested annually through normal maintenance associated with leak detection devices or constantly
monitored systems. Tank testing companies that are engaged to test Line Leak Detectors will need to be accredited by the
manufacturer and or the distributor of the leak detection equipment. Links to reference documents are within the appendix 1.8

VR2 testing

Tank testing companies that are engaged to test VR2 equipment are required to be accredited by the manufacturer and or the
distributor of said equipment.
As the testing and certification of VR2 equipment is heavily influenced by local regulatory compliance set against the equipments
performance, EIT companies must be aware of the said equipment performance criteria and regulations that govern its use.

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Testing Equipment
All equipment to be used within the area designated by the client as exhibiting a higher risk shall be intrinsically safe and the
equipment manufacturers or test authorities proof of compliance shall be available on request.
• The equipment shall NOT be operated outside the operational limits as stated by the equipment manufacturer or
acknowledged test authority.
• The equipment shall be maintained in line with the equipment manufactures specification/recommendations. Prior to
inspection all equipment shall be checked for damage. Any damage that influences the intrinsic safety capability or
functionality of the equipment shall result in denial of that equipment for the test.
• All pressure measuring device(s) shall be bench calibrated using either a reference gauge or incline manometer. Calibration
shall be performed at 20, 50, and 80 percent of full scale. Accuracy shall be within two percent at each of these calibration
points. Calibrations shall be conducted on a frequency not to exceed 90 days.
• The procedure shall include information on the type and brand of equipment
• The procedure shall include a clear description on how to set-up the equipment.

Vacuum pump and tank connections


• The vacuum pump that is dealing with gasoline vapours must be intrinsically safe, coping with EXD regulations and be
positioned in the “safe” area (zone 2).
• The pump shall be equipped with a vacuum type pressure gauge with a reading resolution of maximum 10 mbar (1kpa
increments)
• The pump shall be equipped with an integrated safety valve that can and shall be set at a minimum pressure (e.g. –250
mbar) to avoid plastic collapse of the tank.
• Fittings shall tightly close off all tank openings to a level well beyond the system sensing detection level.

Water level sensing device


• A water level sensing device shall be used that has a repeatability of maximum +/- 1 mm. Because the repeatability accuracy
has a strong influence on the test duration for significant water ingress measurements validation evidence of the claimed
accuracy is required.
• The procedure shall state the type of sensor, the measuring principle and the method of application.

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The ullage positioned acoustic microphone


• The microphone shall be positioned in the ullage.
• The microphone shall be sensitive for the sound from a possible gas jet. Consequently the sensitivity spectrum of the
microphone shall be most sensitive in the range between 10 and 50 kHz. The sensitivity shall allow for a minimum detection
of an induced leak rate of 0.37 litres per hour (0.1 gallon/hour) under the test conditions.

The “hydrophone”
• The “hydrophone” shall be positioned in the liquid phase.
• The hydrophone shall be sensitive for the sound of rising bubbles as a result from air ingress in the liquid phase.
Consequently the hydrophone shall be most sensitive in the range between 4 kHz and 8 kHz. The sensitivity shall allow for a
minimum detection of an induced leak rate of 0.37 litres per hour (0.1 gallon/hour) under practical conditions pertaining noise
levels.

Mass Probes
• Mass detection probes must be positioned at the bottom of the tank, tanks must be at a minimum of 75% SFL before testing
to obtain the best results. Tank bottom must be free of scale and rust a clean surface must be obtained. Location of the probe
can be via direct dip, dewater or fill port preferably with internal tube in place so as to locate probe at tank centre.
• Microphone (hydrophone) should be located within 3 meters of any possible leak source.
Noise signals are recorded so that test data can be reviewed by the test operator or other qualified individuals.
Since the method depends on an audible interpretation of the signal, the test must be conducted under reasonably quiet
conditions.
Vibrations due to heavy traffic, nearby trains, or construction activities could produce sound levels that could compromise the
test.

Earphones

• An earphone shall allow the operator to listen to the received sounds in order to discriminate between leak signals and
background noise. For the acoustic microphone a frequency shift mode shall allow the operator to hear and evaluate the
relevant frequency range. •
• The operator sound system shall allow for easy switching between the microphone and “hydrophone”.

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Functionality requirements.

Verification of equipment performance prior to use

The status of the equipment shall be verified on damage and functionality. The performance of the sensing and measuring
instrument(s) shall be verified at intervals not to exceed 3 months when in use, or immediately following repair and/or modifications.
Functionality test Depending on the type of sensors to be used, functionality and sensitivity demonstration test shall be executed as
described in the test procedure.
• Inspection tags are required to validate and must be attached to the equipment at all times e.g. information should include
date of last inspection
• The tank test company will have a procedure and process for the Verification and recertification of equipment, this should be
made available on request and service records should be kept with the testing equipment on site
• Licensees must abide by the Licensors validation and certification procedures; the Licensor is responsible for ensuring
Licensees are following testing protocols and equipment verifications.

Gauges and measuring equipment

• If mechanical pressure gauges are employed, the maximum incremental graduations of the pressure gauge shall be 10mbar
and the minimum accuracy of the gauge shall be three percent of full scale. The minimum diameter of the pressure gauge
face shall be 4 inches.

• If an electronic pressure-measuring device is used, the full-scale range of the device shall not exceed 0-150mbar with a
minimum accuracy of 0.5 percent of full-scale.

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Contractor Requirements

1. The tank-testing contractor shall prepare the required documentation (procedure). The inspection procedure shall control the
set-up, execution and reporting of the testing. The inspection procedure shall include the details on which the client shall
provide information in order to allow proper test preparations, preferably in the form of a detailed service request form, see
example appendix 1.4.
1. The procedure shall be submitted to the client for acceptance.
2. Personnel, which carry out the test, evaluate the data and work out the reporting, shall be trained and have proven
experience in the application of the test method and the inspection procedure. The contractor shall make the personnel
qualification details and an overview of their experiences available to the client. Based on a review of the inspection
procedure, and the personnel qualifications and experience details, the client may require a third party qualification of the
procedure, equipment and personnel.
3. Before each test the client shall provide the service provider with the required details (to be stipulated in the inspection
procedure).
4. The service provider shall review the provided information and will ask for additional information when required. The service
providers will set-up a detailed test plan. Any operational aspect shall be discussed with the client, especially those aspects
that influence availability and safety. Aspects that may lower the detection threshold shall be discussed prior to the test.
5. The test will be carried out according to the inspection procedure and when required a specific test plan.
6. Immediately following completion of a test, a written field report shall be provided to the client. As minimum the field report
shall include concluding statement pertaining leak tightness. When applicable any procedure deviation including their
(anticipated) effect shall be included too.
7. Full reporting shall be provided within 10 working days after testing, or as agreed in the contract.

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Personnel requirements
The inspection shall be carried out by personnel who shall:

1. Have received a proven and auditable class room training of minimum 32 hours in the test method, to incorporate as
minimum all influential parameters, equipment features, practical aspects, HSE (Health, Safety and Environment) and data
evaluation.
2. Be trained in the field and have proven experience of a minimum of 3 months and 20 UST tests in the application of the test
method.
3. The contractor shall make the personnel qualification details and an overview of their relevant experiences available to the
client on request.
4. The licensor of the test protocols should ensure that all licensees have a current certification card with a set expiration date.
5. The licensor is responsible for the audit which includes checks for the recertification of equipment, personal training and
updates for any regulatory or technology changes. Notification of changes to be forwarded to the DS CoE
6. Be accredited by the local industry standards as applicable
7. Be trained in the Shell PTW system to the minimum level of, Permit Holder

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Minimum Service and Reporting Requirements

The intention of the minimum service and reporting requirements are to ensure EIT contractors set-up, perform and report in line
with the requirements and intentions as per the technical requirements outlined within their certification and Shells requirements for
servicing and reporting.

Initiated by Shell or its representatives the EIT contractor shall prepare all the required documentation. The documentation shall
control the set-up, execution and the reporting i.e.

1. The documentation shall include the details that Shell or its representatives need to provide in order to allow proper test
preparations, in the form of a Detailed EIT Request Form. See example appendix 1.4
2. The documentation shall be submitted to Shell or its representatives for acceptance.
3. The EIT contractor shall review the provided information and will ask for additional information when required
4. The EIT contractors will set-up a detailed test plan. Any operational aspect shall be discussed with Shell or its
representatives, especially those aspects that influence the availability of the EIT and or require additional safety preparations
for the EIT companies to operate
5. Immediately following completion of a test, a verbal field report shall be provided to the Shell or its representatives
6. Full report is required following the minimum reporting requirements as set out within this document.

EIT companies that meet Shells contractor accreditation; industry standards and testing criteria must have the following minimum
service levels and reporting processes in place

• All associated and certified testing equipment including access capabilities, barricades and signage
• Detailed Service Request Forms
• Online booking, online reporting and confidential customer links. In areas where this is not possible the contractor will provide
written reports.
• Response time to call out, 1 working days or as agreed with Shell or its representatives and or local maintenance contracts
that include minimum call out requirements
• Onsite diagnoses and offsite Quality Assurance capabilities
• Tank tester shall maintain call up log of tightness test failure reports. All confirmed failures must be immediately reported to
Shells Representative to allow immediate removal of relevant product from service

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• The Tester shall log the date which the product has been taken from service
• Record retention, minimum 7 years or as per local regulatory compliance
• Record Recovery within 3 working days of request

Reports must contain


• Site Identification and Purchase order confirmation
• Shell or its representatives request and formal communications, all additional correspondence
• Work clearance and JHA information
• Site configuration, boundaries and reference features
• Tank size and associated dispenser numbers
• Tank and dispenser configuration map
• Type of system (e.g. suction or pressure)
• Location of, Dip, fill, ATG and man way, tank top sump orientation
• Vent position
• Locations of isolations and associated check lists
• Water level at the start and finish of test (at both ends of tanks where possible)
• Fuel level at start and finish of test
• Test time and pressure set points
• Pass or Fail
• Location of failure
• Recommendations for further testing
• Certification certificates

Please note, Shells requirements for record retention are,


For all records and correspondence associated with EIT, for the life of the site or transfer of ownership

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Permit to Work requirements for EIT


The EIT contractor shall apply with the Shell PTW system. Tank testing under normal conditions i.e. where tanks and pipe work are
accessible and no isolations are required is considered a Level Two activity i.e.

1. Work Clearance, mandatory on all sites and renewed every day


2. JHA, Site-specific information identifying the risks, controls and actions required by the contractor to mitigate hazards onsite.
Note, a generic JHA is suitable for the standard set up of equipment and testing procedure, they are not site specific and must be
accompanied by a site specific JHA

Undertaking EIT in some cases requires the isolation of associated equipment e.g. product pipe work, dispensers, integrated VR
systems and Vents may require separation from other UPSS onsite.
In most cases the isolations can be conducted from tank access points or tank chambers positioned above the UST however, Any
works associated with the EIT that sees the contractor enter a confined space or is placed in an activity outside of the normal
procedures for EIT, must be reassessed under the PTW system e.g.

1. Work Clearance, mandatory on all sites and renewed every day and identifies high-risk work associated with the testing i.e.
outside the normal scope for testing
2. JHA, is prepared and discussed with Shell or its representatives, EIT technician applies for a Permit to Work
3. PTW, Shell or its representative issues a PTW, EIT technician operates within the agreed work scope and procedure as
outlined by the JHA under permit conditions

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Site Preparation for EIT


Site preparation for EIT is required when tank systems and pipe work are manifolded and require physical isolation; requests for this
will be contained within the Detailed Service Request Form, appendix 1.4.

Tank construction parameters (e.g. wall thickness, construction material) are not of influence on the detection method however;
associated piping systems can influence the outcome of the total system.
In this case experienced tank installation contractors may be required to isolate system pipe work and prepare the site for testing,
other equipment that may see specialised works prepared prior to testing are;

Integrated pressure and suction systems, siphons


Vacuum testing can siphon product from an adjoining tank manifolded with common pipe work. Pressure systems should be
isolated at the submersible pump with ball valve and Suction systems will need to be disconnected at the manifolded pipe work
Looped pressure dispensing delivery lines will need to be isolated i.e. all dispensers on a common line will need to be isolated while
under test

VR1 and VR2 systems


Manifolded tanks with common VR systems will need to be isolated unless a full system test is being performed; when testing
individual tanks manifolded VR and Vents will need to be isolated.
On VR2 systems, central systems and independent systems contained within dispensers will need to be isolated, hanging hardware
should not be pressurised in association with pipe work, seek manufactures recommendations for testing complete VR2 systems.
Note disconnecting common Pipework can lead to operational issues with tanks breathing, tanks isolated from the test (those not
being tested) need to maintain free venting

Vent float valves


Overfill valves located on vents will need to be removed so vents can be tested separate from the tank

Changing out damaged or worn fill adaptors and caps


Fill and dip adaptors are common areas for failed testing, air ingress while testing at this point can fail the system, ensure all
adaptors and fittings are in good order.

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Tank Top Isolations


Direct buried fittings may need to be uncovered so the EIT Company can isolate and test, this should be undertaken by an
experienced UST contractor prior to EIT.
EIT companies and Shell or its representatives should identify this requirement within the Detailed Service Request Form when
possible. EIT technicians can undertake modifications however; this must be in agreement with Shell or their representatives.
All costs associated with work conducted outside of the normal testing procedure must be identified and approved before work
commences.

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Appendixes

1.1 Approved EIT Contractors and Technologies


The following table list approved tank-testing companies in order of preference i.e. 1 being the most preferred, a company that best
meets Shell requirements under this specification and is globally accessible to our business.
Checks should be made with the company as to the countries they operate in, links to current web information attached.

Test Method Company East EU Americas Africa


1. Vacutect http://www.tanknology.com/international.html    
2. Alert Ullage www.alerttechno.com   
3. Masstech http://www.masstech.com.au/qt.htm   

1.2 Choosing an alternative tank test


Tank testing companies that meet this criteria and method are Shell preferred however, not always available in all locations.
Choosing another tank test method may be required and the NWGLDE has been chosen as a complete guide when assessing
alternative tank testing methods and requirements under this standard.

EIT companies, which are nominated under the NWGLDE as approved and certified but do not meet the above criteria (Vacuum
Testing) must be approved under this standard by the Design Standards team. The DS CoE will assist and provide approval when
alternative tank testing companies are to be used.

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1.3 Detail Service Request Form


Sample Only
Shell EIT Detail Service Request Form
Tank Testing Co.

Contact
Site

Address

Site Contact Contact No.

PMC/FMC Co. PM Contact No.

Date of Test Arrival Time


Site Specific
Instructions

Equipment to be Tested
Specific
Instructions

Tank No. Tank No. Confirmation from Test Company


Product ID Product ID

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Product Lines Product Lines


Fill Fill
VR VR
VR2 VR2 Additional comments and requirements
Vent Vent
Full system Full system
Tank No. Tank No.
Product ID Product ID Signature
Product Lines Product Lines
Fill Fill
VR VR Print Name
VR2 VR2
Vent Vent
Full system Full system

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1.4 Existing procedures for investigating Loss, PLIP

Within Shell a system to investigate losses associated with the reconciliation of all products stored in UPSS is in use.
PLIP (Product Loss Investigation Procedure) is a step-by-step process that identifies loss associated with SIRA (Statistical Inventory
Reconciliation Analysis) and product reconciliation procedures.
In the advent that SIRA is not used the process for PLIP is still relevant using the local operators reconciliation information.

PLIP A – Product loss investigation undertaken firstly by the site then the Retail Wet Stock Analyst. This involves reconciling all
product movement including deliveries.

Daily Reconciliation
This is undertaken by the Site operator on a daily basis. If they are unable to reconcile fuel then a PLIP A is initiated
If the site can not identify the reason for the loss, or the loss is attributed to equipment issues the PLIP A is escalated to a PLIP B.

PLIP B – On site product loss investigation involving checking all equipment and system components.
The PLIP B is the on site investigation and EIT that needs to be carried out to determine the source of failure associated with the
product loss.

The PLIP B is undertaken by the Retail Field Engineer, L2 FMC or PMC, the Engineer remains responsible for its completion.

If testing the system indicates the system is tight and there is no explanation for the losses, then the Wet Stock Analyst is advised
and monitoring of the site continues.

PLIP C - The investigation undertaken once it has been determined that product has been lost to the environment.
The PLIP C procedure is the engineering and environmental activities undertaken once a loss of containment in conjunction with a
loss of product has been identified.

Engineering activities relate to taking action to prevent any more loss from the underground systems and rectification of leaking
equipment.

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Environmental activities relate to identifying the effects of a loss, development of a remedial action plan and then the implementation
of that plan. The specific procedures follow by the Environment Services team are not identified in this document and links to these
are given.
Once the implementation has commenced the PLIP C procedure is complete and the ongoing remedial works are identified as an
environmental project.

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1.5 When to Initiate EIT

When initiating an EIT the reasons for testing can differ, once the problem is identified pin pointing and directing the tank test
company to the specific issue helps in setting the scope for the test. The more information around the history of the system will
make the diagnoses clearer and help in making a decision for the end result i.e. repair and re-commissioning.

Primary reasons for initiating an EIT


Note Any sudden loss of product should involve system closure until the loss can be accounted for.
Prior to the EIT the system must be isolated and made safe, continual use of a failed system can result into additional product
release and possible contamination.

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Action Engage Engage Check Close Conduct Symptoms and Comments


PLIP A PLIP B Site system Test
Equipment and ASAP
before EIT test
Issue
Product Loss     SIRA and onsite manual reconciliation can detect losses associated with the ongoing operation of the
site. EIT can be called when losses are detected, see PLIP procedures appendix 1.5
SIRA and
Reconciliation
Equipment   Dispenser hesitation, slow filling of tanks, ongoing dispenser shut down

Breakdown
Equipment   PLLD alarms (slow pumping), Interstitial Monitors (low brine level alarm)

Alarms
Equipment  When conducting repairs or replacement that requires cutting or removing pipe work, man
ways, threaded couplings, change out of STP’s or of the primary tank connections.
Replacement
and repairs
Water Ingress   High water alarm ATG, or detected water onsite dipping. Water detected through dispensers
customer complaints
Filtration   Slow Pumping, continuous cleaning of filters. Ethanol products should check particulate levels
in fuel sample see Ethanol Conversion Guidelines
issues
Product    Onsite or offsite PSH, Close system and test, check reconciliation of product
Engage PLIP C procedure
Outside
Containment
Regulatory   Formal request local regulator for EIT

Request
Environmental  Compliance test as per local conditions to operate.

Compliance

Regulatory compliance and periodic EIT are not reasons for system closure unless they are directly related to ongoing complaints
and issues with the operating system, a decision to close should be discussed with all parties concerned, if in doubt close the
system and test.

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1.6 Failure Types


Tank Shell, Wet Failure.
When tank shell failure is confirmed within the wetted area of the tank i.e. tank shell area below fuel level, this requires immediate
action and formal notification through the PLIP once the EIT company confirms the test result

1. Formal notification from the tank test company to PM/Engineering


2. Shells representative to initiate PLIP C, formal notification required
⇒ Shells representative to arrange for tank test company or contractor to “Tank Lock Out” Hazard Caps fitted to fill and dip
points, site operators informed
⇒ Shells representative to contact, Logistics, Sales and Operations informing of the isolation of the tank from the system.
⇒ Shells representative to arrange for product removal
⇒ Shells representative to contact Shell environmental contract manger to undertake formal soil/groundwater mitigation plan
⇒ Arrange for repairs and or replacement of UST
⇒ Re-certify repairs, recommission and open

Note; Indirect and Direct Fill lines are considered as part of the wetted tank area and need to be isolated along with the tank until
repaired.

Tank Shell, Dry Failure.


Tank shell ullage i.e. failure within the tank shell above fuel level, is deemed a tank shell failure unless the failure is identified as
ullage associated Pipework e.g. Vent pipe and Vapour Recovery.

Failure with pipe work associated with ullage will not require tanks to be pumped out however, pending the type of failure i.e.
particularly with Vent/VR systems could see water ingress via pipe work into the tank which would cause tanks to be closed.
In some countries where VR1 and 2 systems form part of the vapour monitoring tanks will need to be closed, local regulatory
conditions for UPSS should be checked.

Product Line Failure,


Pressure delivery lines, Fill lines and Suction lines all need to be isolated from the system before dispensers, pumps or filling of
tanks can be brought back on line. Lines need to be repaired and retested before they can be operated.

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1.7 Failure Types and Actions

The following table is a guide for actions associated with failure types. Note that in some countries continuing to operate any part of
the system with a known failure is prohibited until repairs and re-certification.

Action Close Tank Remove Isolation and Re-test and Continue to


(Cannot Accept Product Repair before Certify before Dispense from
Deliveries)
Failure Type use use Tank (if no water
present)
Tank Shell Wet    

Tank Shell Dry    


(Ullage)
Tank Top    
Fittings
Fill Line Failure    

Pressure Line  

Suction Line  

Vent    

VR 1    

VR 2   

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1.8 Reference Documents

• D&S CoE
Shell Design Standards EIT Reference Documents

• OG.04.20065 - Recommended selection of leak detection methods for Underground Storage Tanks (UST’s) as to be applied by
SRI

• Shell Retail Permit to Work Training, Standards, and Checklist


External HSSE web page for contractors access linked off of the www.shell.com site for implementation of PTW and other HSSE
projects

• HSE Golden Rules – Comply, Intervene, Respect

• PLIP Procedures
https://sww-knowledge.shell.com/knowhow/livelink.exe/Open/96261290

• NWGLDE
The, National Work Group on Leak Detection Evaluations

• Ken Wilcox and Associates Inc.


KWA

• Leak Detectors
http://www.franklinfueling.com/service/pdfs/sps/400439001.pdf
http://www.franklinfueling.com/service/pdfs/sps/TB002r0504.pdf
http://www.veeder.com/page/Mechanical_Line_Leak_Detection

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