Out of service equipment

[rocketscientist]

I'm working with a client's P&IDs. One drawing shows me an atmospheric tank that is tagged, "out of service." The tank was in service with gasoline. The pump suction line is blinded but the fill line is not. In fact, the P&ID shows the fill line valve as open. The conservation vent has been removed but an atmospheric vent has been installed.

EPA requirements for an out of service tank establish that a tank must be flushed clean and all lines shall be blinded. Obviously, this is not the case for the fill line.

I think the other line should be blinded based on API standards, which I can't seem to find at the moment. Certainly, allowing gasoline to be vented to the atmospheric is not allowed per EPA regulations.

What do you think?

 

[Duwe6]

Other than being poor practice, nothing 'illegal' about a filled 'dead leg'.

Not having the tank clean is wrong, not having the fill line blinded is wrong.